Supplementary memorandum from British
Airways plc
This memorandum responds to supplementary
questions submitted by the Environmental Audit Committee, following
the hearing on Wednesday 11 February.
(i) [Q219] While the Committee understands
the efforts the aviation industry has made, and is continuing
to make, to mitigate environmental impacts, it remains unclear
as to why you think that the White Paper does not represent a
"predict and provide" approach?
The inference of the phrase "predict and
provide" is that infrastructure capacity is being provided
to meet a predicted level of demand, irrespective of the environmental
consequences. That is not the approach of the White paper. Rather
the government has set clear environmental targets and limits
which will need to be met if development is to proceed.
This is particularly so in the case of a third
Heathrow runway, which is the most important development for British
Airways contained in the White Paper. The government has made
clear that this development can only go ahead if local air quality
limits around Heathrow can be respected, and noise disturbance
contained within a contour of 127 square kilometers. The government
has also made clear that it expects to take measures to limit
the contribution of aviation to global warming, with the inclusion
of aviation within EU emissions trading as the first step forward
in this process.
So in terms of the key environmental impacts
of aviation—noise, local air quality and global warming—the
government is setting conditions which will need to be met if
airport developments are to proceed, very different from the idea
of "predict and provide" which takes no account of the
environment.
(ii) [QQ254-257] Can you clarify what
you mean when you suggest that the EU emissions trading scheme
should also take into account the economic benefits that aviation
delivers?
While the UK government and the UK aviation
industry are supporting the proposal to include intra-EU aviation
in the EU emissions trading scheme, we have yet to have any meaningful
discussion of how permits will be allocated and targets set. Domestic
aviation emissions are already contained in national inventories,
but there are no existing inventories or targets for international
emissions laid down in the Kyoto protocol.
In deciding what targets might be set, it is
important to strike a balance between the environmental objective
(the need to reduce emissions) and the cost of achieving that
objective. The notion of striking a reasonable balance between
economic, social and environmental criteria is embodied in the
principle of sustainable development.
It is also important that we seek to maintain
a broadly level playing field between airlines based in different
EU countries, and that airlines based in the UK are not competitively
disadvantaged because our government has set more ambitious targets
than other European governments.
(iii) [Q263] You referred to the stance
of the United States as not helpful in ICAO discussions. Could
you comment a little more on this?
The US government has made it quite clear that
it does not support the approach set out in the Kyoto Protocol
to tackle global warming. They are therefore reluctant to see
any measures agreed within ICAO to tackle global warming beyond
voluntary measures.
If the US government was more persuaded of the
case for policy action, it is likely that they would want to see
an approach based on emissions trading, as all the analysis points
to this being the most cost-effective way ahead. The US stance
on Kyoto has therefore deprived emissions trading of a strong
natural supporter in the ICAO discussions.
(iv) [Q271] Could you clarify the
basis on which the figure of 15.1 million tonnes CO2
is calculated—in particular, whether it includes emissions
from all international flights and all related ground-based activities?
The figure of 15.1 million tonnes (15,149,000
m tonnes) is the reported figure for aircraft emissions of CO2
in 2002-3, taken from our latest Social and Environmental report.
A further 150,000 tonnes of CO2 are generated by ground
energy sources in the UK. Ground energy sources outside the UK
are not monitored for climate change purposes, though the bulk
of BA ground facilities are in the UK.
(v) The White Paper refers to an urgent
programme of work and consultation to examine the issues surrounding
a third runway at Heathrow. Does British Airways consider that
a decision to go ahead should be made on the basis of this work?
Or should the Government wait until 2010 to assess how far the
NOx limit has been met before sanctioning a further runway?
We hope that rapid progress with the programme
of work on Heathrow air quality will allow a decision to be made
in 2006, when the government has said it will review progress
against the White Paper framework, or very soon after that. Leaving
this decision until 2010 would make it difficult to achieve the
2015-2020 target completion range set by the government for a
third Heathrow runway. The earlier that a third Heathrow runway
can be delivered, the greater will be the economic benefits to
the UK economy, our aviation industry and to the travelling public.
March 2004
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