Supplementary memorandum from the Aviation
Environment Federation
We appeared before the Committee at an oral
evidence session on Wednesday 11 February 2004 and were asked
to respond with some further details on the subject of future
ICAO CAEP derived aircraft NOx standards and their relation to
the local air quality picture around Heathrow airport. We also
said we would submit our full response to the Department for Transport's
White Paper consultation process, which we have sent to the Committee's
Clerk on a CD.
We add a very short commentary on the recently-released
Department for Transport background paper "Aviation and Global
Warming", January 2004 plus an update on the current process
for deciding how to allocate emissions from international air
travel through ICAO and UNFCCC/SBSTA.
The Department for Transport recently released
its background paper "Air Quality Assessments Supporting
the Government's White Paper `The Future of Air Transport'",
December 2003. This contained a comprehensive review of how forthcoming
EU limits for NOx might potentially be controlled and reduced
around Heathrow, Gatwick, Stansted and Birmingham airports. The
document found a major and very significant problem at Heathrow
and a smaller potential exceedence at Gatwick requiring "tough"
mitigation and almost no difficulty at Stansted or Birmingham.
The analysis majored on the problem at Heathrow
and ran a number of scenarios and sensitivity tests as follows:
— New aircraft fleet mix data for forecast
year
— Revised 2002 aircraft type base data
with an assumption that the new aircraft available would reduce
NOx emissions by an average of over 25%
— New road emission factors likely
to be introduced by the European Commission, though not yet officially
formulated
— Revised method for estimating background
NO2 levels
— Reverse idle for aircraft (where
relevant)
— Reduced thrust for aircraft (where
relevant)
— Preconditioned air available on all
aircraft stands plus mainly fixed electrical airside power units
— New method for calculating near road
NOx/NO2 conversion ratios
— Changes to the airside vehicle fleet
giving a 50% reduction in NO2
— Changes in on-airport holding patterns
with a 30% fall in delays
— Various scenarios for future aircraft
NOx performance CAEP/4 -31%, 34%, 40% and a "limited"
-15% option, all achieved through tighter international standards,
landing charge pricing and operational changes
— Displaced "start of roll"
take off procedures, partial mixed mode operations
— Optimised speed limits on M4, no-growth
in non-airport related traffic on M4 over current levels
— Zero emissions from M4 and airport
spur between M25 (J4A) and Cranford (J3) and airport spur by placing
9 km of motorway road network in tunnel with vent stacks and scrubbers
removing all NOx
— 15 different scenarios using various
combinations of some and/or all of the above with different operational
parameters ranging from 480, 515, 550, 600 & 655 ATMs with
and without new 3rd "short" runway and/or current 2
runway maximum use variants as well
— "Total population exposed"
outcomes in excess of NO2 limit value in range from 6 to 22,900,
number of dwellings exposed range from 27 to 9,422
— Overall study shows huge difficulty
in getting LHR area down to EU limit value for NO2
This highly complex mix is described as an attempt
to provide a "best estimate" of air quality around airports,
moving away from what was felt to be the "conservative"
approach adopted previously. Both BAA plc and British Airways
have provided the DfT with new aircraft and airport operational,
measurement and modelling data and suggestions, which the Department
has used in its calculations.
The information provided by BAA plc and BA resulted
in lower air quality impacts than had previously been the case.
The DfT also include in their assessment methodology a new way
of calculating near-road NOx/NO2 conversion rates, which tends
to show increased NOx. These new information sources do not cancel
each other out in terms of volume contributions.
The tables on pages 25, 20 & 30 of the report
show in detail the results we have reproduced in short form above.
We believe that the DfT assessment shows that
it is very difficult to solve the air quality problem around Heathrow
airport right now and that moving beyond the current planning-approved
number of 480,00 ATMs would make matters worse. The DfT are reasonably
correct in their analysis of where improvements could be sought
but dangerously over-optimistic in their application of both the
scale and timing of the scope for reducing and controlling NOx
related air quality impacts from most, if not all sources, in
such a way as might ensure compliance with EU limit values.
In our view, it is the continued additional
burden of aircraft and airport operational related emissions growth
that is the main problem here, which, when coupled with the proximity
and density of housing and people around Heathrow, makes compliance
almost impossible to achieve.
We were asked to comment on how the new ICAO
CAEP NOx stringency rules could affect the Heathrow situation.
To recap on our oral evidence, the NOx stringency options for
consideration at ICAO CAEP were:
-5, -10, -15, -20, -25, and -30, all being percentage
improvements below the current CAEP 4 standard.
We promoted and lobbied for -30% as did ACI,
the airport's representative body; UK Government, supported by
other European countries, said -20%; US, manufacturers and IATA
about -10% and Canada didn't see the need to do anything! The
result was a compromise figure of -12% together with a decision
to further review the standard at CAEP 8, which is likely to be
in 2010.
This will lead to a NOx increase for the worldwide
aircraft fleet of between 148-151%, whereas at -30% the increase
would have been would have been in the region of 140%. All figures
are for the period 2002-20. This is because forecast growth outstrips
technological and operational improvements.
The standard comes into effect for new engines
in production from 2008. There is no phase out of non-compliant
engines. There are no exact figures for the number of existing
in-production engines that would fail to meet the new standard
as the analysis produced for CAEP only looked at 5% intervals.
However at -10% and -15% the existing in-production engines that
failed were 34% and 47% of the worldwide fleet respectively.
Paragraphs 4.2.1 to 4.2.6 are the DfT's analysis
and commentary on NOx production from aircraft engines—we
broadly agree with this, apart from paragraph 4.2.4 and the analysis
it contains of how regulatory and market based measures might
drive down NOx emissions. We feel this is an over-optimistic claim.
DfT and QinetiQ then derived 3 cases for future aircraft related
NOx performance, which were then used in the sensitivity testing
described previously in conjunction with revised future fleet
data.
Paragraphs 4.2.5/6 are vitally important and
we agree with their contents, which comment that "average"
aircraft engine emissions from the standard ICAO database differ
from the "characteristic" values that are a better representation
of in-service performance. As a result actual NOx emissions may
be underestimated by around 13%. Para 4.2.6 in particular relates
NOx emissions to aircraft type, size and popularity at Heathrow
and states that: "there are risks that the mass of NOx will
rise (especially at Heathrow) despite the increasing fuel efficiency
of the engine."
Figure 1 below is reproduced from the DfT paper
and shows how, despite what we consider to be optimistic views
of future technology and fleet composition aircraft related NOx
at Heathrow will increase substantially.
Source: DfT "Air
Quality Assessments" report December 2003
The failure to agree a progressive new NOx
standard at the recent ICAO CAEP meeting means that the scenarios
used to develop the NOx emissions graph above are over-optimistic
and that the likely future volumes of NOx would be higher. Even
if a more stringent standard can be agreed in 2010 at CAEP 8 it
is likely to have a later date for entry into force. Future standards
are therefore likely to have a minimal impact on the fleet much
before 2020. The model assumptions need to be changed to reflect
this outcome and the graph redone. If pressed, we would say Heathrow
NOx emissions from aircraft could potentially be 5-10% higher
for all ATM/runway combinations as a result of the new NOx standard
falling below the estimates used in the projections shown graphically
in Figure 1 above.
Finally, it might be useful if the Committee
knew the cost implications that ICAO produced as part of their
analysis for member state decision-makers:
The undiscounted incremental cost impacts
(manufacturer and operator costs, including loss of fleet value)
of NOx stringency options for the period 2002-20, assuming the
standard takes effect in 2008, are:
5% $1,629 million
10% $3,618 million
15% $10,244 million
20% $16,886 million
25% $49,739 million
30% $67,023 million
Source: UN ICAO CAEP/FESG
papers 2004.
As is usual with ICAO's member states decisions,
their collective choice of new standards invariably settles on
one of the least ambitious environmental improvements, at the
lowest cost end of the scale of available options.
We will press the DfT to re-run the assumptions
in this paper again in the light of the disappointing ICAO CAEP
NOx stringency decision.
The other recently released White Paper background
report is "Aviation and Global Warming", DfT, January
2004. This report is an analysis written largely from an economic
viewpoint and covers the following areas:
— UK domestic carbon emissions and
targets, including Kyoto and the DTI Energy White Paper's aspirational
60% reduction target
— Aviation emissions, both globally
and the UK's projections
— Aviation's contribution to global
and UK emissions targets
— Costs of reducing global emissions,
focusing on emission trading schemes and the scope for savings
in other sectors
— 5 annexes looking at future CO2
forecasts, technology assumptions, future fleet mix and fuel efficiency,
and a brief overview of 2 studies, the first an assessment of
economic incentives from CE Delft, the second the RCEP Special
Report on aircraft and climate change.
The analysis in the report is largely a review
of current research on the specific areas that could provide a
base for developing policies to control and reduce air transport's
emissions and global warming potential, which we welcome. We are
pleased to see that the report and the White Paper acknowledge
the necessity of including the critical radiative forcing multiplier
that results from air transport's atmospheric emissions being
greater than CO2 alone in its calculations and policy
development suggestions.
The main area we would like to bring to the
Committee's attention is where the report seeks, quite rightly,
to try and ascertain if under any emissions trading scenarios
(global or EU) enough reductions in CO2 output form
other sectors could be found to offset the growth in air transport.
This is simple maths and can be estimated irrespective of any
analysis of ultimate costs and economic efficiency.
Paragraphs 4.10 to 4.13 of the report and their
accompanying graphs put domestic and international UK forecast
emissions from 200 to 2050, with a 2.5 radiative forcing multiplier
weighting added in Table 2, in the context of the Energy White
Paper targets.
Paragraphs 4.12 and 4.13 state:
4.12 The forecasts for aviation emissions
including radiative forcing in 2020 in the graph above approach
40 MtC, or about 15 MtC more than actual in 2000. This increase
would correspond to more than the reduction in baseline for other
sectors in the EWP envelope (see table 2 above).
4.13 If aviation were faced with the
same 30% reduction in emissions as in the EWP envelope over the
1990 to 2020 period, the cutbacks in aviation and/or other sectors
clearly would be significantly greater.
Source: "Aviation
and Global Warming", DfT January 2004
And in paragraph 5.24, when discussing the OXERA
BAA plc funded study "Assessment of the Financial Impact
on Aviation of Integration in the EU Greenhouse Gas Emissions
Trading Scheme",the DfT report readily acknowledges the difficulty
of finding enough carbon savings in any system to support the
growth in air transport thus:
5.24 . . . Tight targets for 2050, in
particular, assume that sufficient carbon offsets can be obtained
from other sectors. This may not be the case.
Source: "Aviation
and Global Warming" DfT January 2004
If we look at both this background document
and the White Paper in the round, it is clear that, as we acknowledged
in our earlier linked submission to the Committee, the Government
acknowledges the problem that air transport emissions growth on
the scale that the expansion forecast in the White Paper would
bring and has also raised some concerns around the uncertainty
of this growth and the tools to tackle it.
But, for instance, putting their weight behind
discussing aviation's inclusion in the EU trading scheme is not
the same as being able to guarantee to deliver an effective scheme.
What the White Paper has done is effectively "green light"
the growth in airport capacity whilst faced with issues it has
no effective solutions to. Government policy is that the UK must
see passenger numbers rise from 180 mppa to 470 mppa by 2030 and
tolerate the consequent environmental impacts, accepting the commercial
imperative as sacrosanct. The mathematics of emissions trading
simply do not add up, as the "Aviation and Global Warming"
paper indicates. The White Paper is regrettably not a sound basis
for developing policies that can actually control and reduce air
transport's contribution to global warming, due to the absence
of any specific reduction target for the sector.
We would ask the Committee to request that
the DfT, DTI and DEFRA jointly review the White Paper analysis
together; decide where emissions trading and charges could go;
and try and set a target for real greenhouse gas reductions by
the UK air transport sector in the light of the EWP targets and
any achievable reductions and cross-sectoral allocation potential
under either a trading or charging framework.
We would like to bring to the Committee's attention
the important question of how best to allocate air transport's
international emissions. The DfT has adopted option 5 for analytical
convenience in the various papers and reports surrounding the
White Paper policy process. We support this stance as a pragmatic
way of at least being an essential first step in understanding
and examining this important topic.
In addition to our representational role at
ICAO CAEP, we undertake a similar function at the equivalent European
body ECAC ANCAT. We submitted and presented the following Information
Paper at the group's September 2003 meeting in Paris, in an attempt
to seek some resolution to this apparently thorny question and
to discover the exact position regarding the preferred allocation
choice of each of the 41 countries, plus the EU as observers,
who make up ECAC.
ECAC/ANCAT Information Paper submitted
by Jeff Gazzard from "GreenSkies" Alliance -September
2003
Allocation of International Bunker Fuel
Emissions from Air Transport.
We are very concerned about the lack of progress
at the UNFCCC SBSTA body in deciding how to allocate the international
emissions from air transport. We would like to make two points
that we hope member states, the Commission and ECAC as an entity
can study quickly and go onto develop a clear policy statement.
There were 8 original options for allocation
as follows:
1. No allocation—presumably a programme
of voluntary action through ICAO
2. Allocation of global bunker sales and
associated emissions to parties in proportion to their national
emissions
3. Allocation according to the country
where the bunker fuel is sold
4. Allocation according to the nationality
of the transporting company, or to the country where an aircraft
or ship is registered, or to the country of the operator
5. Allocation according to the country
of departure or destination of an aircraft or vessel; alternatively,
emissions related to the journey or an aircraft or vessel shared
by the country of departure and the country of arrival
6. Allocation according to the country
of departure or destination of passengers or cargo; alternatively,
emissions related to the journey of passengers or cargo shared
by the country of departure and the country of arrival
7. Allocation according to the country
of origin of passengers or owner of cargo
8. Allocation to a party of all emissions
generated in its national space.
SBSTA decided that Options 1, 3, 4, 5, and
6 should be the basis for further work on this issue (UNFCCC,
1997).
For us, the only options worth considering
are 3 and 5—however we understand it may not be so straightforward
for shipping, which is part of the delay. There may be an opportunity
for ECAC members to contact their maritime equivalents within
their respective Governments/regulators and for the ECAC/ANCAT
Secretariat to contact the IMO to ascertain any difficulties and
to help resolve them.
We understand that there is an associated
issue of definition i.e. how to consistently identify domestic
and international emissions and how they can best be reported.
There are currently reporting differences between UNFCCC/IPCC
and ICAO methodology. There is an on going dialogue to resolve
this—the original timetable was for ICAO to report to SBSTA
at SBSTA 19 (this December), but ICAO has requested further time
and will now report to SBSTA 20 in June 2004.
Please note that this topic is not the
same as the allocation issue for which there is no timetable that
we are aware of.
We would therefore ask member states, the
Commission and the ECAC/ANCAT Secretariat to:
— confirm that the reporting differences
between UNFCCC/IPCC and ICAO will be resolved before SBSTA
20
— contact their maritime equivalents
and the IMO to ascertain any difficulties and to help resolve
them
— inform ECAC/ANCAT which allocation
option they favour in writing by the end of September 2003
— ensure ECAC/ANCAT reaches a consensus
view on its favoured option for the allocation of international
emissions by mid-2004 before the SBSTA 20 meeting as a convenient
mile stone
— ensure as rapidly as possible
that a timetable is urgently established to get ICAO to adopt
the ECAC preferred allocation option—we have the end of
2004 in mind
It is simply impossible to make any significant
progress on how best to control and reduce air transport's emissions
unless the allocation and reporting issues are finalised. For
once it would be good to see regulators responding favourably
to what we consider to be a sensible request and timetable.
Unfortunately we were unable to get any positive
responses at all from any member state or observer, in this case
the EU, at this time.
Subsequently at COP 9/SBSTA 19 in December 2003,
it was agreed that decision 2/CP3, relating to allocation, would
be pursued at SBSTA 22 scheduled for summer 2005. This is yet
another years delay!
The Sixth meeting of ICAO's Committee for Aviation
Environmental Protection (2-12 February 2004) failed to endorse
a proposal from the UK Government requesting ICAO to invite SBSTA
to give a high priority to work on an allocation methodology,
although the meeting did note the outcome of SBSTA 19.
A recent written reply from the European Commission
services, in response to a questionnaire from the Danish Presidency
contains a preliminary analysis of the different allocation options
showing, for international emissions from aviation, a preference
for allocation according to fuel sales, ie option 3. This is the
de facto EU position.
We are grateful that the UK/DfT tried to get
this issue moved on, although without a statement on what the
UK's allocation preference might be, and we are pleased that at
least the EC has expressed a preference which is a significant
step, particularly as it's one of the options we favour, the other
being option 5.
We would be grateful if the Committee could
ask the Government to clarify its official allocation preference.
However, all of this ridiculous delay and prevarication plainly
shows that most member states simply are not interested in any
progress on this issue. This leads us in turn to seriously question
whether ICAO and ECAC member states intend to ever develop a policy
on emissions trading or charges in these policy arenas. There
is a gaping policy vacuum here .We wonder if the Committee has
any contacts with its counterparts in other EU member states and
could perhaps try and spark some interest in moving the international
debate along?
March 2004
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