1. In the last twelve months, the Environmental Audit
Committee (EAC) has published two reports on the environmental
impacts of aviation. The first, Budget 2003 and Aviation
published in July 2003, arose out of our regular appraisal of
the Treasury's environmental tax policy and the scope for using
fiscal instruments to shift the burden of taxation from 'goods'
to 'bads'. 
It was prompted by our concern that the Treasury and the Department
for Transport (DfT) should give full weight to environmental impacts
in developing the Government's future aviation strategy. The Government
response to our report was published with The Future of Air
Transport White Paper in December 2003.
2. Our reaction to The Future of Air Transport
White Paper was one of disappointment and we decided to focus
on aviation as part of our review of the December 2003 Pre-Budget
Report. We published this second report, Pre-Budget Report
2003: Aviation follow-up, on 15 March 2004.
The nineteen conclusions and recommendations contained in it
are reproduced here at Appendix 2 to this report. In accordance
with the normal two month deadline, the Government formally responded
on 18 May. Its response is printed at Appendix 1 to this report.
3. In our view, the quality of this latest response
is poor and not of the standard we would normally expect. For
this reason we are now asking the Government to provide a further
response to some of the specific issues we raised. We have also
taken the opportunity to comment on some additional issues which
have emerged in analysing the figures provided in the department's
The Government Response
Form and Content
4. Government responses to Select Committee reports
normally follow an established protocol: departments set out
individual conclusions or recommendations and respond in detail
to each. They may sometimes group together two or three recommendations,
and this may be acceptable where the latter are interrelated in
such a way that discussion of one necessarily entails consideration
of the others. However, in this case, the Government has not
only failed to quote the emboldened text from our report, but
has grouped them together en masse in such a way as to
avoid having to respond individually to each.
5. The following table sets out in a highly summarised
form the nineteen conclusions and recommendations our report contained,
together with an analysis of the extent of coverage in the Government
||Is there a response?
|1. Early availability of supporting documents
||Response does not fully address the issue of early availability of documents - in particular, Aviation and Global Warming.
|2. The White Paper adopts a 'predict and provide' approach, and the Government is actively promoting growth.
||Response fails entirely to address the second part of the Committee's conclusion.
|3. Lack of detailed studies on future distributional impacts of growth.
||The DfT has not indicated what research it has carried out and with what results.
|4. Need for a formal statement of what the DfT understands by sustainable consumption in the context of air travel, and how forecast growth relates to J'Burg commitments.
||The response nowhere even mentions sustainable consumption or discusses this recommendation.
|5. The Integrated Policy Appraisal in the White Paper is very weak on climate change impacts.
||No specific consideration.
|6. Specific consideration must be given in all policy appraisals to impact on carbon target.
||EAC welcomes progress on this. (It made a similar recommendation in July 2003.)
|7. Need to consider including the risk of catastrophic impacts in the cost of carbon.
||EAC awaits with interest the report of the interdepartmental group.
|8. The DfT did not include in appraisals the full environmental costs of aviation growth.
||[See 9 and 10]|
|9. The DfT has not calculated total producer and consumer surpluses to set against the total environmental NPV of minus £42 billion.
||No specific consideration.
|10. Need for a revised environmental appraisal
||The DfT only states that it has no plans to publish any new or revised appraisal.
|11. No policy instruments proposed other than including aviation in the EU ETS.
||The response refers cursorily to this topic, but only in an international context. It does not discuss any measures the UK could take such as introducing VAT on air ticket sales, increasing APD, or developing a UK emissions charge.
|12. Lack of commitment to promoting within the EU an interim emissions charge.
||The response contains only the briefest of comments on the difficulties of introducing a charge on an international basis.
|13. Lack of research to underpin the inclusion of aviation in an EU ETS. DfT should set out what needs to be done and by when.
||No specific consideration of this conclusion and recommendation, despite evidence by a DfT official of the need for urgent action here.
|14. Extent of consensus in EU on including aviation in ETS from 2008 is unclear.
||Some discussion of this topic, but no indication of the range of opinions.
|15. Poor prospects for progress internationally (in ICAO etc)
||The DfT appear to have misunderstood the Committee's comments here. EAC agrees that the prospects of any progress within ICAO are very poor.
|16. Acceptance of EAC figures for aviation emission and need to take account of radiative forcing.
||The DfT appears to accept the principle of including radiative forcing and the scale of the figures set out by EAC.
|17. The ETS cannot accommodate a huge growth in aviation at the expense of other sectors.
||The DfT does not address this fully on the grounds that the issue can only be faced if and when international emissions are assigned to national inventories.
|18. The 60% target is unattainable.
||The figures in the Government response would imply that the UK might only manage a 34% total reduction.
|19. Need to acknowledge difficulties in order to focus policy development. Govt should not rely on technological improvements as the scope for these is limited.
||The response acknowledges the difficulties, but fails to indicate any commitment to developing any alternative policy responses.
6. The table above demonstrates that the DfT has entirely failed
to respond to five conclusions and recommendations, even though
some of these are very specific and do not overlap with any others.
In addition, the responses to many other conclusions and recommendations
were inadequate. We therefore do not accept the Government's opinion
that the Committee's criticisms are 'unfounded', particularly
since the DfT has made scant effort to refute them.
7. 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.
Demand forecasts and behaviour
8. One of the key criticisms of the White Paper which
we set out in our previous report is that it adopts a "predict
and provide" approach to future growth and that the Government
is actively promoting growth on the scale envisaged. As examples
of the latter, we set out in paragraph 10 of our report the statements
in the programme of action in the White Paper: "we expect
the airport operator to move quickly to develop the detailed design
for a new runway at Stansted and associated development
We will institute immediately a programme of work on how to make
the most of Heathrow's existing runways and add a new runway after
the Stansted runway."
9. Yet the Government response contains only one
paragraph relating to this issue and even that is largely irrelevant.
Two of the bullet points cited relate to the need for economic
growth, one to the need for planning certainty, and three to the
need to mitigate the impacts of airport development at a local
level. The last point relates to the wider environmental impacts
of air transport, yet the claim that the White Paper "ensures
that over time aviation pays the external costs its activities
impose on society at large" is misleading: the Government's
only proposal on this score is the commitment to incorporate aviation
within the EU Emissions Trading System, but in our view the likelihood
of achieving this in the foreseeable future is minimal. There
are no proposals or stringent criteria here to ensure that future
growth is contingent on it being truly sustainable, and indeed
the DfT has conspicuously failed to explain what sustainable consumption
means in the context of air travel.
10. 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.
11. The Government response also misleadingly implies
that we recommended that aviation growth should be "stopped
in its tracks" with airport capacity limited to its 2000
level. It is unhelpful when the Department wilfully misunderstands
and misrepresents the position we have set outnamely, that
it should have based its strategy on a reduced rate of growth,
rather than on either no growth at all or satisfying forecast
demand. We remain deeply concerned that the White Paper assumes
a 1% decrease in air fares in real terms until 2030. Among the
other questionable assumptions on which this is based was the
crucial forecast that the price of oil will remain on average
25$ a barrel in real terms (2000 prices).
The events of recent months make this look increasingly dubious,
and there is a certain irony in the fact that growth may ultimately
be restricted by external factors rather than the adoption of
a positive strategy by the Government itself.
12. In this connection we also expressed concern
about distributional impacts of the proposed rate of growth.
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.
13. The concept of sustainable consumption is fundamental
to any discussion of this topic. The recommendation in our report
specifically on this topic was completely ignored in the Government
response. We restate it here and invite the DfT to consider it.
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.
14. A number of our recommendations related to the
manner in which DfT appraised the environmental impacts of the
proposed growth in aviation. Individual studies undertaken as
part of the SERAS and RASCO exercises included substantial modelling
of environmental impacts at a local levelsome of which
revealed potentially serious issues. The environmental appraisal
of a third runway at Heathrow, for example, revealed that further
development might not only breach NOx statutory emission limits
but could also have a serious impact on the availability of water
15. However, our main concern was that environmental
impacts were not being adequately addressed at a strategic level.
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.
16. 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
Inclusion of aviation in the EU
17. The Government's only policy response to address
the impact of aviation on global warming is to work for the inclusion
of aviation in the second round of the EU Emissions Trading System
from 2008, and this is to form a key objective of the UK presidency
in 2005. In our previous report, we quoted evidence from DfT
officials that further work especially on modelling cross-sectoral
impactswas essential even to draw up initial proposals,
but that nothing was currently being done.
18. 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.
Aviation and the 60% target
19. In our previous report on aviation, we were concerned
at the lack of readily available and commonly agreed statistics
on aviation emissions and their impact on future carbon reduction
targets. We therefore set these out in a table which we reproduce
here for reference, and highlighted the fact that by 2050 aviation
emissions would amount to 66% of total UK domestic emissions.
|Millions of tonnes carbon (MtC)
|1. Aviation (excluding RF)
|2. Aviation (including RF @ 2.5 times) [line 1 x 2.5]
|3. UK domestic emissions
|4. Total UK emissions, including aviation but not RF [line 1+ line 3]
|5. Total UK emissions, including aviation plus RF [line 2 + line 3]
|6. Aviation (including RF) as a percentage of UK domestic [line 2 ÷ line 3]
|7. Aviation (including RF) as a percentage of total UK [line 2 ÷ line 5]
(1) Figures for aviation and UK emissions are based
on DfT's Aviation and Global Warming (Dft, January 2004).
(2) The radiative forcing (RF) factor is based on
that used by the Treasury in its document Aviation and the
Environment: using economic instruments (March 2003).
20. The Government response criticises this table
for being 'misleading and inappropriate' on three grounds:
- double counting of domestic
- portraying aviation as a percentage of UK domestic
emissions (rather than of total emissions including aviation);
- not including other greenhouse gases in total
UK domestic emissions.
21. On the first point, we accept that there is a
minor inaccuracy in the table. But the scale of it is very small
and the effect is that we have actually underestimated the impact
slightly. If domestic aviation is excluded from the 65.8 MtC
2050 target, the figure will fall to about 64.2 MtC and total
aviation emissions as a percentage of UK domestic carbon emissions
will rise from EAC's original estimate of 66% to 68%.
22. On the second point, the DfT have entirely failed
to notice that we did indeed include in our table figures for
aviation as a percentage of total UK emissions (including its
share of international aviation emissions). However, our purpose
in comparing aviation emissions with the 60% target for 2050 (65.8
MtC) was to emphasise the unsustainability of DfT's projections.
It is inconceivable that the UK will allow aviation to expand
to emit the equivalent of 44 MtC in 2050 at a time when all other
sectors of the UK economy are constrained by a target of about
64MtC. The larger the growth of aviation the more misleading it
would be not to compare it directly in this way. We therefore
stand firmly by the manner in which we have highlighted this percentage
(66%). Indeed, we note that the DfT agreed to the scale of our
original figures in a previous response;
and that RCEP has itself quoted a figure of 70% for aviation as
a percentage of UK emissions on much the same basis as ourselves.
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
23. On the third point, it is quite true that we
based our figures on the 65.8 MtC target for 2050 which was set
in the Energy White Paper, and on figures contained in DfT's own
document "Aviation and Global Warming". We did
so for the very good reason that the Government has failed to
clarify how its 60% reduction target relatesor does not
relateto greenhouse gases other than carbon dioxide. In
the Energy White Paper itself, the Government constantly refers
to the 60% carbon reduction target in the same breath as the need
for greenhouse gas reductionsas exemplified in the very
paragraph in which the target is set:
2.12 Our ambition is for the world's developed
economies to cut emissions of greenhouse gases by 60% by around
2050. We therefore accept the RCEP's recommendation that the UK
should put itself on a path to a reduction in carbon dioxide emissions
of some 60% from current levels by about 2050. In this white paper,
we therefore set out the first steps to achieving this goal.
24. But in its response, the Government has attempted
to massage the aviation percentages downwards by including non-CO2
greenhouse gas emissions at a fixed level until 2050. It states
that "the UK total including radiative forcing comprises
CO2 from the EWP [Energy White Paper] target envelope
plus GHGs [Greenhouse Gases] put conservatively at 25.8 MtC equivalent
in 2030 and 2050." This figure of about 26 MtC
represents exactly the same amount of greenhouse gases (excluding
carbon dioxide itself) as were emitted in 2002.
In calculating its own figures for aviation emissions in relation
to other UK emissions, the Government is therefore assuming that
there will be no reduction in greenhouse gases, other than carbon
dioxide, over the next 50 years. Indeed, on the basis of DfT's
figures, the forecast percentage reduction in combined total emissions
by 2050 (including all aviation) will only amount to 34% rather
than 60%. This figure
agrees very closely to the 35% which we calculated.
25. 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.
Accuracy of figures in the Government
26. The table included in the Government response
is itself not unproblematic.
The figures for UK domestic emissions of carbon dioxide in 2000
and 2030 (152.2MtC and 100.4MtC) do not agree with the equivalent
figures in DfT's Aviation and Global Warming (147 MtC and
98.7 MtC). Moreover, the figures for UK domestic emissions in
2030 and 2050 do not appear to be consistent in both parts of
the table. The figure of 94.0 MtC in part 2 of the table, for
example, does not equal 65.8 MtC (part 1 of the table) plus 25.8
MtC (note to table).
27. Such inconsistencies, while admittedly relatively
minor, reflect the fact that the DfT has devoted insufficient
attention to these issues. Part 4 of DfT's Aviation and Global
Warming contains a relatively brief discussion, and fails
to set out the data in a comprehensive and transparent way. It
does not, for example, contain any data on UK domestic aviation
emissions or UK greenhouse gas emissions (either excluding or
including domestic aviation). 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.
1 EAC, Ninth Report of Session 2002-03, Budget 2003
and Aviation, HC 672. Back
HM Treasury, The Government Response to the Environmental Audit
Committee's Report on Budget 2003 and Aviation, December 2003,
Cm 6063. Back
EAC, Third Report of Session 2003-04, Pre-Budget Report 2003:Aviation
follow-up, HC 233. Back
Appendix 1 (Government response). Recommendations 1 to 10, 11
to 15, and 16 to 19 are grouped together. Back
Appendix 1 (Government response), paragraph 3. Back
See paragraph 13 below. Back
Department for Transport, The Future of Air Transport,
Cm 6046, December 2003,Annex A paragraph 7. Back
DTLR, SERAS Stage 2: Appraisal Summary Tables, February 2002. Back
The figure of 64.2 MtC is derived from DfT's figures in Appendix
1 (81.6 MtC combined total emissions minus 17.4 MtC total aviation). Back
EAC, Third Report of Session 2003-04, Pre-Budget 2003: Aviation
Follow-up, HC233-ii, Ev76. Back
DfT, Aviation and Global Warming, January 2004, paragraph
Provisional figures for 2003 show total emissions at 179 MtC and
CO2 at 153 MtC.See http://www.defra.gov.uk/environment/statistics/globatmos/gakf05.htm. Back
Based on DfT figures in Appendix 1 (ie the reduction from 202.0
MtC in 2000 to 133.5 MtC in 2050). Back
EAC, Third Report of Session 2003-04, Pre-Budget Report 2003:Aviation
follow-up, HC233, paragraph 45. Back
Appendix 1 (Government response), table. Back