Memorandum submitted by the Aviation Environment
"The Government should set itself a target
for reductions on carbon dioxide emissions in the transport sector",
said Sir John Harman, chairman of the Environment Agency. "There
is a mismatch in government policy between its aviation and carbon
The Observer Newspaper Business Section, 19
"Aviation will remain dependent for the
foreseeable future on fossil fuel. As such, there is a powerful
case for aviation to take up some of the world's capacity to absorb
greenhouse gases, after key human development needs such as clean
water, food and sanitation in both developed and developing countries
have been met. Importantly, this would only be permissible by
aviation minimising its impacts through technology and operational
improvements, and meeting the external costs of its remaining
emissions. Discussion has centred on emissions trading as the
policy most likely to yield most environmental benefits at least
"A strategy towards sustainable development
of UK aviation", Sustainable Aviation umbrella pamphlet Society
of British Aerospace Companies, Airport Operators Association,
et al, June 2005.
"Everyone's carbon dioxide emissions must
go to zero to allow for aviation pollution reveals major analysis
of UK climate change targets."
Tyndall Centre for Climate Change Research
Press Release headline, September 2005
The Aviation Environment Federation is the UK's specialist
environmental NGO working exclusively on developing control &
reduction strategies for aviation's negative impacts. For full
details of what we do please go to www.aef.org.uk
We are pleased to be able to contribute to the
EAC's present Inquiry, "Reducing Carbon Emissions from Transport"
and will try to answer the Committee's questions as they relate
to our area of interest and expertise.
What progress the DfT is making against
key carbon reduction targets or forecasts included in the Ten
Year Plan (2000), the Climate Change Strategy (2000), the 2004
Transport White Paper, the 2004 PSA, Powering Future Vehicles
(2004), and other documents.
We can identify no specific carbon reduction
targets for air transport across the entire range of relevant
Government documents, although the problem of growing carbon emissions
from air transport is acknowledged and analysed. In fact quite
the oppositethe underlying documentation
to the Future of Air Transport White Paper, December 2003, forecasts
CO2 emissions from the sector rising from around 5
Mt C in the late 1980's to 16-21 Mt C by 2030 and 16-29 Mt C by
The figures quoted above are CO2
only (as C). But the particular difficulty with aviation greenhouse
gas emissions is that other pollutants including NOx, plus other
effects such as condensation trails and cirrus cloud formation,
all increase the radiative forcing impact from aircraft engine
exhaust emissions. These additional impacts are accounted for
by a UN IPCC-derived simple multiplier commonly expressed thus:
total climate change impacts are a factor of 2-4 times greater
than those from aviation's CO2 emissions alone. This
range is interpreted as a straightforward 2.7 multiplier on aviation's
CO2 forcing which has become a widely accepted rule-of
We should point out that work continues on reaching
a better scientific understanding of these issues. Below is a
short overview of where "the science" is right now:
The EU-funded "TRADEOFF"
project is a model-based project investigating the atmospheric
impact of aviation. Its final 2005 report suggested that the RF
contribution from condensation trails is somewhat less (10 mW
m-2) than the IPCC 1992 estimate (20 mW m-2) but is greater for
cirrus cloud formation. Only a wide range could be given for cirrus
RF (10 to 80 mW m-2, cf 0 to 40 mW m-2 from IPCC, 1999) but the
underlying analyses showed more certainty of a positive linkage
between air traffic and enhanced cirrus over the IPCC analysis.
The total "TRADEOFF" radiative forcing for aviation
in 2000 is approximately equal to the IPCC 1992 estimates since
some forcings increased with traffic (CO2), while others
were reduced from improved modelling and underlying assumptions.
This resulted in an overall RFI of 1.9. However some key scientists
involved in these issues believe that the RFI does not reveal
aviation's full environmental response, which could, measured
in terms of a temperature response (non-equivalent) be approx.
3.5 times greater than the impact of aviation CO2.
Key Fact: TRADEOFF report shows slightly reduced
RFI contribution from aviation emissions excluding cirrus but:
The TRADEOFF project attributed a
potential RF multiplier for 2000 of 1.9 times greater than CO2
alone: however, if the additional impacts of cirrus cloud formation
are included, the range is 2.3 to 5.1 with a mean estimate of
3.1. This compares with the IPCC best estimate for 1992 of
2.7 with a range from 1.9 to 4.0. The TRADEOFF project team
decided that the uncertainty range for cirrus was large and that
further work was needed on this topic.
Key Fact: TRADEOFF report indicates cirrus cloud
formation impacts potentially severe but more work needed
The five-year QUANTIFY project, 35
members from 16 states with a budget of 8-12 million over
the 2005-10 period, is looking at Quantifying the Climate Impact
of Global and European Transport Systems from road, air and maritime
sources. This project is carrying out a parcel of work to take
the TRADEOFF analysis on aviation emission-induced condensation
trails/cirrus cloud formation forward. There are some early indications
that this investigation will attribute a significant positive
RF factor to cirrus cloud formation confirming that there is a
serious problem with these impacts. It is unlikely to produce
definitive results for another 18-24 months, however.
Key Fact: QUANTIFY is an important and hopefully
definitive research project especially with regard to aviation
emissions induced cirrus impactsits work should be monitored
There is also a move by climate scientists,
including those associated with the authoritative CICERO (Centre
for International Climate and Environmental Research) institute,
and others, that the Global Temperature Potential (GTP) metric
is a strong candidate for replacing Global Warming Potential (GWP).
An enhanced GWP ie GTP could provide better opportunities for
policies that cover a larger part of man-made radiative forcing
(RF), improving comprehensiveness and cost-efficiency. This metric
would tend to increase the resultant surface temperature effects
of aviation's total contribution to climate change.
Key Fact: GTP believed to be better metric than
GWP, scientific opinion and research must be clearly identified,
tracked and communicated to policy makers.
A crucial issue is what can conventionally be
done to reduce and control greenhouse gas emissions from the sector.
There are limited but relevant discussions in the Air Transport
White Paper concerning the role technology and operational improvements
could play in generating important efficiency savings, the "mitigation"
options, thus making the growth in carbon emissions "less
than it otherwise would be".
The ATWP does include a section in Chapter 3,
pages 39-41, on climate change and explains emission trading as
a concept at Annex B. Measures discussed include:
air traffic control measures to minimise
the impact of these activities on climate change;
more R&D to reduce the climate
change impact of future fleets;
voluntary action including emissions
reporting and targets at company level;
emissions trading, either an open
system developed internationally through ICAO or participation
in the EU scheme from 2008; and
hint of possible emissions charge
in paragraph 3.42, page 41, with a commitment to move forward
if progress at international level proves towards ETS "too
What these pages show, however, is a superficially
reasonable but understated grasp of the problem and a less than
in-depth examination of any outcomes resulting from the policy
measures being considered. It is this almost total lack of any
targets as to how to reduce and control the sector's climate change
impacts, coupled with a very limited and short-term analysis of
the reductions needed from other sectors in the economy that would
be needed to "feed" air transport's growth under any
emissions trading scheme scenario, clearly making the running
as the Government and industry favoured solution, that is most
This seems to us to be an unacceptably lightweight
area of the White Paper. In our previous submissions to the Committee
we have made the point that emission trading is a potentially
flawed concept as a total solution to aviation's climate change
impacts. Firstly, no agreement has yet been found on how to include
aviation's non-CO2 impacts and secondly, no analysis
has been undertaken to establish what fraction of CO2
emissions aviation will use in long term scenarios targeted at
climate stabilisation, which underpins UK policy through the Energy
White Paper and the EU "2 degrees" policy. We have made
and will continue to make this point directly to Government and
the EC as well. We simply don't agree either with the Government's
statement in paragraph 3.43 of Chapter 3 of the ATWP that "because
of its blunt nature, Air Passenger Duty is not the ideal measure
for tackling the environmental impacts of aviation."
APD is an effective proxy for the lack of fuel
duty and VAT on tickets and set at the right level, with perhaps
a distance related component, to achieve effective pollution reduction
targets through demand management would work well. However, we
understand that such a policy doesn't fit the Government's thinly
disguised "business as usual" predict and provide scenario
set out so uncompromisingly on every page of the ATWP.
It is generally accepted by most commentators
that the UN IPCC 1999 analysis published in the Special Report
on Aviation and the Global Atmosphere still holds true, that is
to say that improved aircraft engine and airframe design could
contribute around a 1% per annum fuel efficiency gain through
to 2020. Better load factors, ATM, satellite GPS routeing
and other operational gains could add a similar 1% system efficiency
gain over the same period. We welcome all aerospace R&D programmes,
both here in Europe and the USA that help move towards ensuring
these ambitious mitigation goals are met. But the IPCC analysis
concluded that CO2 emissions are likely to increase
at 3-4% per annum over the same periodthus the growth in
CO2 emissions continues to outpace the efficiency gains
better technology and improved operations can reasonably be expected
to bring. Our later evidence will try and identify solutions that
could help to close this gap.
The DTI Energy White Paper, February 2003, stated:
"We need to reduce the emissions from aviation
. . .
5.22 Demand is rising in the aviation sector
internationally at about 4% per year. We will all benefit from
the growth in business, services and our ability to travel. International
aviation emissions currently do not count in the national inventories
of greenhouse gas emissions. There is no international agreement
yet on ways of allocating such emissions. The UK's international
emissions currently amount to some 8MtC ((MtC including domestic).
They are expected to rise to some 14-16 MtC by 2020.
5.23 We are committed to ensuring that the
long-term development of aviation is sustainable and that it meets
its external costs. We are discussing with stakeholders the most
economic instruments for ensuring that the industry is encouraged
to take account of, and where appropriate reduce, its contribution
to global warming. We will set out our plans in an Air Transport
White Paper. Potential instruments to address CO2 emissions
from international aviation being considered include an en route
emissions charge and participation in an en route emissions permit
trading scheme. For domestic flights British Airways has joined
the UK emissions trading scheme. There may be opportunities for
future participation in this scheme for other carriers who operate
(Note: the bold emphasis above is the White Paper's)
None of the background papers to the DTI EWP
calculating how and where sectoral savings through to 2020 might
be made contain any reference to the air transport sector. There
are some references to extending the ETS but again no mention
of air transport's inclusion, although to be fair, this work does
precede the ATWP.
The Government's First annual report on implementation
of the Energy White Paper, April 2004, said this about aviation
"2.9 Carbon savings from the transport sector
remain challenging and are relatively expensive when compared
to other sectors. We are, however, developing policies to improve
the carbon efficiency of transport which will have an impact over
the nest decade. This work includes promoting the development
and take-up of new technologies and fuels. We shall set out our
strategy for increasing the amount of biofuels used by road transport
in the UK later this year. The Air Transport White paper has committed
the Government to press for the aviation sector to be included
in the EU ETS as soon as possible. And we are pressing the European
Commission to finalise a further round of Voluntary Agreements
on new car fuel efficiency with the automotive industry."
The most recent DTI review Reducing Carbon Emissions,
July 2005, also features the ETS commitment:
"2.17 International aviation emissions
do not count in the national inventories of greenhouse gas emissions,
as there is no international agreement yet on ways of allocating
such emissions. However, we are committed to ensuring that the
long-term development of aviation is sustainable and that it meets
its external costs. The Future of Air Transport White Paper set
out our aim of including aviation in the EU ETS from 2008 or as
soon as possible thereafter. The European Commission has work
in hand, looking at how best to address the climate change impacts
of aviation, including emissions trading. A Communication by the
Commission suggesting a way forward is due in July. We expect
to debate the options and agree a way forward during our EU Presidency."
And the DFT's Autumn Performance Report 2005
repeated this policy in Chapter 7, "Reduce greenhouse gas
"Most transport emissions count towards
targets under the Kyoto Protocol, including emissions from domestic
aviation. Emissions from international aviation and international
shipping, however, do not count and there is no agreement on how,
or whether, to allocate emissions from these sources to individual
We believe that the best way of making aviation
contribute towards stabilisation is through a well-designed emissions
trading regime and this has been a key focus of the UK Presidency
of the European Union. This is why we are backing the inclusion
of aviation in the EU Emissions Trading Scheme and are also continuing
to press for the development and implementation, through the International
Civil Aviation Organisation, of an international emissions trading
The front page of this submission features a
small extract from the Government-endorsed, in the shape of the
Prime Minster, industry-produced Sustainable Aviation strategy
pamphlet. The climate change section of this document contains
a Commitment number 6, page 21, stating that:
"Airline and airport signatories to build
support and assist policymakers in developing practical solutions
for inclusion of aircraftCO2 emissions in the EU Emissions
Trading Scheme by 2008, or as soon as possible thereafter, as
a first step towards a global approach."
Unsurprisingly there is a neat symmetry between
this air transport industry commitment and Government policy.
This would be fine if it could achieve absolute reductions in
greenhouse gas emissions from this sector. But paragraph 3.37
of the ATWP tells us the Government's true position:
"Reduction in greenhouse gas emissions across
the economy does not, however, mean that every sector is expected
to follow the same path. The Government is committed to a comprehensive
approach, using economic instruments to ensure that growing industries
are catered within a reducing total. The use of emissions trading
allows coverage of environmental costs through a mixture of emissions
reduction within the sector and purchase of reductions that can
be produced more cheaply by other sectors."
The ATWP therefore clearly sees growing greenhouse
gas emissions from this sector as an acceptable price to pay for
the linked economic activity. But its central policy outcome,
that air transport emissions will be offset by reductions elsewhere,
But what if the industry's greenhouse gas emissions
with or without the additional NOx, contrail and cirrus burdens
cannot be managed by the preferred policy combination of efficiency
gains, mitigation, and emissions trading?
The much vaunted technology and operational
efficiency gains need to be identified much more accurately than
at present and measured and reported on annually to monitor mitigation
progress. We need to see:
what international R&D programmes
are underway with what targets and at what cost in the fields
of engine and airframe technology; what results are forthcoming
against the targets and when; how and when these programmes will
become aircraft production reality; accurate forecasts of in-service
dates and fleet wide replacement and performance gains
Key requirement: mandatory Government-led annual
reporting of air transport technology greenhouse gas mitigation
progress not industry-led voluntary efforts;
similar identification of ATM programmes
and other airline-focused operational measures including emissions
inventory reporting and efficiency parameters, such as emissions
per revenue kilometre. with progress towards targets audited on
an identical annual basis;
Key requirement: mandatory Government-led annual
reporting of air transport ATM & operational greenhouse gas
mitigation programmes again, not industry self-reporting.
We have a gut feeling that if and when aviation
emissions are part of any ETS all these supply-side efficiency
gains will be smartly attributed to an "ETS effect".
We believe that the technology and operational gains identified
as possible by ACARE, Eurocontrol and the other actors capable
of implementing such supply-side gains, would in all likelihood,
happen anyway. We know this because they have already been identified
pre-ETSthey are a welcome part of the industry's correct,
albeit with an increasing degree of difficulty given the distinct
possibility of costly diminishing returns, and admirable drive
to reduce operating costs. However, identifying and bringing technology
to the market place is one thing. Encouraging the uptake of that
technology, especially where it involves early re-engining or
fleet replacement will still require a substantial incentive or
price signal. Forecast ETS prices alone are unlikely to drive
market uptake, so even if the manufacturers can deliver, who is
going to buy it?
It is very, very difficult to analyze additional
drivers for supply-side gains in this sector. This is because
the industry is already pretty savvy at R&D and programme
implementation, both aircraft and operations led. The long lead
time from idea through to implementation is an inevitable part
of an industry that has complex multi-faceted, multi-partnered
operational systems. Similarly aircraft are bought and operated
on 30 year cycles, from initial R&D concepts through production
and in-service to end-of-life cycles. This why we need a clear,
mandatory Government-led reporting initiative not voluntary industry
Only then would we be able to monitor exactly
what progress the DfT is making towards this first key element,
the technology and operational efficiency/mitigation improvements,
of its carbon reduction strategy for the air transport sector.
These efficiency gains may well be overtaken by growthwe
still need to know whether they've been achieved. If Government
wants to rely on technology to contribute to the delivery of its
policy goals, then itnot the industrymust be the
one to audit and verify progress.
The second policy element, to work towards the
inclusion of aviation emissions in the European ETS and at the
same time press for an international variant of the same, could
fairly be said to be a strategic goal that might show some progress
against carbon reduction targets. At the moment, however the scheme
is, as they say in Hollywood, under development.
We will move on to discuss the elements needed
to get this latter policy off the ground; if it would make any
difference to further reducing carbon targets over and above what
would have happened anyway, both within and outside the air transport
sector; and what alternatives may be needed to begin to actually
significantly to stabilise & reduce emissions from the sector.
To conclude this section:
For the air transport sector, the
DfT has no clear carbon reduction targets in place, only carbon
growth targets. There are some loose aspirational technology-led
mitigation claims that might make emissions from the air transport
sector somewhat "less worse than they otherwise would be".
There needs to clear cross-cutting Government-led policy initiatives
to drive and develop emissions reduction programmes in the key
areas, aerospace technology, ATM and operational efficiency gains
that could make a readily identifiable mitigating contribution,
even if subsequently outpaced by the sector's growth. There are
no mandatory reporting or auditing programmes to measure any progress
in these areas and there urgently needs to be.
The growth in air transport emissions
could well blow the joint DfT/DEFRA/DTI PSA Kyoto and UK 2010
greenhouse gas reduction targets out of the water. We say this
because it is unclear if emissions from international aviation
are included in the PSA target. We have assumed they aren't. The
DfT might claim that as these emissions are not Kyoto-linked as
such, and ICAO are working on but hasn't any agreed global policy
(and frankly is never likely to agree on one!) to deal with them,
they somehow don't count. But finding a solution, be it the European
ETS or whathaveyou, clearly is an integral part of the ATWP and
the DfT have allocated resources to their preferred policy options.
Surely then all UK-derived aviation emissions should at least
be part of the PSA? Abrogating such responsibility is clearly
irresponsible and unacceptable.
There is little evidence of any carbon reduction
target for aviation emissions.
Whether the DfT's carbon reduction
target is underpinned by a coherent strategy stretching across
the department's entire of activities?
What realistically the DfT could
achieve by 2010 and 2020 in terms of reducing transport-related
carbon emissions, and the role that demand management should play
in doing so?
We have discussed in the previous section why
we feel the DfT's ATWP climate policies, such as they are, lack
clarity and need direction. There is in reality a clear 4-track
strategy for unrestrained growth:
1. Expand the air transport sector's passenger
numbers, consequent infrastructure demands and all its environmental
impacts including greenhouse gas emissions through "predict
and provide" methodology.
2. Justify this increase by citing the alleged
economic benefits based on one analytical study jointly financed
by the DfT and the aviation industry.
3. Discuss aspirational technology and operational
efficiency targets that might make greenhouse gas emissions "less
than they otherwise would be", the industry's mitigation
contribution, but with no central oversight of any such programmes
and no reporting or audit capability regarding their progress
other than voluntary industry self-reporting.
4. Develop a policy that might include aviation
emissions in the European ETS at an unclear future date as your
cornerstone CO2/greenhouse gas containment policy but
stress the sector's pre-determined special case status that growth
must be facilitated by purchasing cheap credits generated by other
industrial sectors and ETS-linked special market measures.
Time for another quote.
On the 16 December 2003, the RCEP had this to
say about the White Paper in a tough, uncompromising, press release:
"The release of today's Aviation White Paper
reveals a serious fracture between the government's policies on
energy and aviation",
said Sir Tom Blundell, Chairman of the Royal
Commission on Environmental Pollution.
Sir Tom expressed the Royal Commission's disappointment
in the White Paper published today by the Department for Transport.
Sir Tom explained:
"The White Paper fails to take account of
the serious impacts that the projected increase in air travel
will have on the environment. Earlier this year the government
published an Energy White Paper setting out its strategy for tackling
global climate change, and set challenging but necessary targets
for greenhouse gas emissions. Today's Aviation White Paper undermines
those targets and continues to favour commerce over vital carbon
dioxide reduction measures."
Last year the Royal Commission's report on air
transport pointed out that uncontrolled growth in aviation, to
the extent predicted by the government, would mean it would become
the major source of global warming emissions in the future, contributing
more than half the UK's share of greenhouse gases and their equivalents
by 2050. The Royal Commission made a number of recommendations
to government on how to avoid this situation.
The Aviation White Paper acknowledges this danger
and the consequent need to take steps to make the cost of air
transport reflect its environmental damage. It even recognises
the role that emissions charges might play in this, as recommended
by the Royal Commission. But it makes no clear commitment to action,
and at the same time it announces a huge expansion in airport
capacity. This leaves a major question mark over the extent to
which the government is serious about the carbon dioxide reduction
targets set out in its Energy White Paper. Aircraft emissions
have between two and three times the global warming effect of
carbon dioxide emitted at ground level.
Sir Tom added:
"The Royal Commission is not opposed to
cheap air travel, and has no intention of suggesting that people
should not have affordable access to their holiday destinations.
However, the levels of growth predicted in the Aviation White
Paper are simply not environmentally sustainable, and the government
needs now to start moderating demand, both by increasing the cost
of air transport to a fair and equitable level, and by encouraging
affordable and environmentally more benign forms of transport."
The Commission advises that the debate should
not be about where to expand air travel capacity but how to resist
In its report last year, the Royal Commission
made five recommendations to government:
impose climate protection charges
for aircraft taking off and landing within the EU;
restrict airport development to encourage
greater competition for available take off and landing slots in
order to optimise their use;
develop major airports into land-air
hubs integrated with an enhanced rail network;
support technological development
to lessen the damage done by air travel;
include international aviation in
the emissions trading scheme under the Kyoto Protocol.
The Royal Commission calls upon the government
to explain how it reconciles the rift between aviation policy
and energy policy, and what measures, such as those proposed by
the Royal Commission, it will adopt to manage demand for air travel."
Unfortunately, the Government ignored this response
at the time and has continued to do so since. Other important
Government advisory bodies, such as the Sustainable Development
Commission, and the UK's executive environmental protection agency,
the Environment Agency, have made similar comments pointing out
the policy dissonance between the UK's greenhouse gas reduction
efforts and the expansion proposed in the ATWP.
The scale of this problem has been investigated
by the well-respected Tyndall Centre for Climate Change Research.
According to the Tyndall Centre's most recent
report "Decarbonising the UK":
"All householders, motorists and businesses
will have to reduce their carbon dioxide pollution to zero if
the growing aviation industry is to be incorporated into Government
climate change targets for 2050"
We present below a short graphical extract from
their findings, which we endorse as a careful and accurate account
of the how the ATWP emissions forecast will wreck the UK's climate
change policies. The first two profiles are what recent scientific
views, 550 ppmv compliance, and the very latest, a 450 ppmv stabilisation
level, regard as necessary to stabilise CO2 in the
atmosphere at levels which could prevent dangerous or catastrophic
climate change impacts.
A further two profiles show what happens when
you add aviation emissions both with and without the toal climate
change multiplier to the contraction and convergence scenario
required for UK emissions stabilisation under both 550 ppmv and
450 ppmv regimes.
Representation of what a 550 ppmv compliant
profile looks like for the UK under a contraction and convergence
regime. This profile is for carbon dioxide emissions (measured
in million tonnes of carbon (MtC)) only.
Representation of what a 450 ppmv compliant
profile looks like for the UK under a contraction and convergence
regime. This profile is for carbon dioxide emissions (measured
in million tonnes of carbon (MtC)) only.
Both the 550 ppmv and 450 ppmv profiles as well
as the carbon dioxide emissions generated by the UK's aviation
industry. This scenario is outlined in the Tyndall Centre/Friends
of the Earth report "Growth Scenarios for UK Aviation".
Key point: aviation exceeds the 450 ppmv carbon budget by 2050.
Source: all graphs: Tyndall Centre report
"Growth Scenarios for EU and UK Aviation: contradictions
with climate policy". The previous graph includes uplifted
carbon emissions from aviation. The uplift factor used is 2.7.
However, the point is that there are additional
and as yet unquantified emissions from the aviation industry that
are likely to significantly increase its impact on climate change,
and this is broadly illustrated in the final graph above.
To view the Tyndall Centre for Climate Change
Research reports on aviation and climate change go to:
"Growth Scenarios for EU and UK Aviation:
contradictions with climate policy"
"Decarbonising the UK"
The AEF and other environmental NGOs have a
clear policy imperative in respect of controlling and reducing
air transport's growing and worrying contribution to climate change.
We want EU-wide policies that ensure:
urgent action is taken to control
and reduce greenhouse gas emissions from air transport wherever
they occur, given the sector's growing contribution to dangerous
regional action soon as there is
little or no prospect for agreement on global measures to tackle
this problem in the short- to-medium term, if ever;
the broadest package of fiscal measures
to tackle aviation's total climate change impact, including taxes,
charges and trading.
We therefore strongly welcome the recent, September
2005, European Commission Communication "Reducing the climate
impact of aviation" and its clear and unequivocal acknowledgment
of these three issues.
We also welcome, as an essential first step,
the Commission's announcement to establish a working group to
develop proposals as to how aviation could best be included in
the EU ETS. Environmental NGO's are participating in this programme
which is due to report by the end of April 2006 with a legislative
proposal due by the end of 2006.
We are pleased to see this policy development
process in place but in our view the actual start date for including
aviation emissions in the European ETS would be 2010 at the earliest,
and in all probability, given the political processes and negotiations
still to take place, is more likely to be 2013. This is a
worrying delay and strengthens our case for demand management
However, including aviation in the ETS must
not become an end in itself. Our support for the final policy
proposals will be heavily dependent on defining effective environmental
criteria to be applied to aviation's inclusion. We have seven
critical benchmarks we will apply as the policy development process
goes ahead. They are as follows:
1. The overall environmental objective and
starting point must be to bring the sectors' emission reduction
targets and any baseline calculations in line with current and
future EU climate targets in particular the EU "2 degrees"
policy and the frequently stated and accepted figures necessary
to move towards stabilizing CO2 greenhouse gas emissions
at around 550 ppmv by 2050, of which the path to 2020 is given
-8% below 1990 levels by 2012 (Kyoto)
-30% below 1990 levels by 2020
A weak ETS that does not achieve the above objectives
will increase the pressure for other regulatory and fiscal instruments.
And emissions from international aviation must be included in
any post-2012 international climate treaty framework despite moves
already underway from oil-producing states and their political
and industrial sector allies to prevent this happening.
2. Well-designed instruments with the widest
geographical coverage that do not discriminate between carriers
on the same routes guarantee there will be no significant economic
distortions that might alter the competitiveness of EU airlines.
Stringent climate policies can be applied to air transport when
compared to the so-called "exposed sectors" which might
be sensitive to cheaper imports and/or production plant relocation.
3. An ETS/air transport policy must address
the full climate impact of aviation. Notwithstanding some degree
of scientific uncertainty, we believe other fiscal policy instruments
should address non-CO2 impacts such as NOx, contrails
and cirrus cloud formation, invoking the "precautionary principle".
Such measures must be introduced in parallel to the ETS.
If such a package cannot be delivered in parallel,
and in order to ensure environmental integrity and the complete
coverage of all impacts via the ETS, we are confident this can
be achieved by using multipliers on CO2 emissions in
a relatively straightforward manner.
4. The policy should have the widest geographical
scope possible, to include emissions from all flights to and from
all EU airports because of the current absence of any global controls
on emissions from international aviation. Our research and that
of others, shows there are no legal barriers in this specific
5. An ETS/air transport policy should aim
to achieve the full internalisation of climate costs, invoking
the "polluter-pays" principle. This should provide airlines
with an incentive to invest in cleaner more fuel-efficient technology
thereby helping reduce emissions.
This is why our clear preference is for the auctioning
of permits. If, however, grandfathering and/or benchmarking are
eventually favoured, the parallel use of other economic instruments,
as the rationale in point 3 above, is an absolute necessity.
6. The development of future climate change
policies presents policymakers with an unmissable opportunity
to contribute to ending the historic and long obsolete tax privileges
enjoyed by the air transport industry. To this end, an ETS/air
transport policy must be part of a package of measures and we
again welcome the Communication's reiteration of its preference,
as a matter of principle, to see aircraft fuel subject to energy
taxes. We welcome all and any initiatives to make this possible
including the consideration of domestic aviation fuel taxes and
VAT on air travel now.
7. Climate change policies should generally
aim to reduce the EU's oil dependency and this includes air transport,
which across Europe consumes 1 million barrels of oil per day.
Skilfully designed ETS/air transport policy instruments should
aim to maximise both demand and supply-side opportunities to improve
efficiency and reduce emissions within the sector. We feel strongly
that it would be a grave miscalculation to rely solely on other
sectors to generate the reductions required by air transport which
must surely be encouraged to reduce its own emissions in some
Source: Tyndall Centre report "Growth
Scenarios for EU and UK Aviation: contradictions with climate
This last graph shows the dramatic forecast
growth in uncontrolled aviation emissions from a selection of
European member states. It requires only a small leap of imagination
to understand the impact this growth would have on the EU "2
We have commented earlier in this submission
about the difficulties of identifying the supply-side contribution
that so-called "mitigation" measures could make
at the risk of ad nauseam repetition, at the levels envisaged
they simply make the air transport sector's emissions "less
worse than they otherwise would be".
As our 7 point-menu above shows, there are some
gaping holes in the way aviation policy makers, and to some extent,
environmental regulators, want this scheme to proceed. Not least
is the startling omission that the essential carbon reducing performance
driver of any ETS, a tough cap that reduces over time, seems to
be missing from all discussions!
A very recent report commissioned by DEFRA and
the DfT "Including aviation in the EU ETS: Impact on EU allowance
prices", ICF Consulting, February 2006, is highly critical
of the assessment of supply-side contributions in the background
appraisal work (CE Delft "Giving wings to emissions trading",
July 2005) to the EC's current EU ETS/aviation policy development
process. It goes on to conclude, after an impact analysis, that:
Adding aviation to the EU ETS using
an assumed allocation base year of 2008, "will not have a
discernible impact on average annual prices of carbon instruments".
Time period for EU ETS Phase II is
only 2008-12there will be only relatively small increases
in aviation emissions in that short timeframe.
Trio of carbon market scenarios lead
to prices in a range 5.30, 11.40 & 21.20 per tonne CO2
These scenarios are "Worst case"
as ICF assume zero absolute reduction in aviation emissions with
very small cost implications due to a low emissions cap.
Very difficult to assume/model supply
side implications over and above already forecast targets of 1-2%
pa from technology and operations ICF stress much more
work needed in this area.
Demand beyond 2008-12 and consequent
aviation emissions growth needs to be set in an EU ETS contextif
the sector's growth continues at around 5% pa, the price implications
for carbon market "have the potential to become more significant"but
no analysis undertaken.
Main source of supply of carbon market
place emissions expected to come from power sector abatement.
Allocation base-year assumed to be
2008 emission levels but ICF critical of this "finger-in-the-wind"
ICF modeling reveals that at least
an additional 150 MtCO2 equivalents would be required
to "induce a noticeable increase in price(s)".
This report has, it seems to us, been produced to
explain and reassure the air transport and other EU ETS participants
that there will be minimum cost implications whatever the sector.
This is exactly why we seek to promote our comprehensive
7-point plan, reluctantly accepting that, however imperfect, including
aviation in the ETS is the policy status quo in the UK.
It remains to be seen if such reassurance works
to calm fears in other energy-intensive sectors. Contrary to the
ICF findings, such sectors are worried, albeit in self-interested
fashion, about aviation's potential future demand for carbon to
reduce liquidity in the ETS market and raise prices as reported
by Andrew Warren, the Director of the Association for the Conservation
of Energy, in an article for the Nov/Dec 2005 publication Energy
in Buildings and Industry, "Is the brave new world of emissions
Andrew Warren noted that at the formal launch
in Brussels late last year of the second phase of the second European
Climate Change Programme, the European-wide trade bodies representing
the alloys, cement, ceramics, glass, iron and steel, lime, non-ferrous
materials, and paper-making industries articulated their fears
that aviation companies, given huge free allocations of existing
emissions will be in a position to afford carbon prices far beyond
the reach of energy-intensive industries, causing a massive market
imbalance. Such claims, whether justified or not, only add to
the political pressure to agree a weak cap for aviation's inclusion.
We have, however, managed to find one part of
the Government that seems to believe air transport should be subject
to some form of demand management as the extract below from the
No 10 PIU Energy Review report shows:
"The Energy ReviewA Performance and
Innovation Unit ReportFebruary 2002
Increased vehicle efficiency and investment in new
options for transport fuels is required in the longer-term.
The transport sector is likely to remain primarily
oil-based until at least 2020. Access to oil supplies is not a
current concern. Nevertheless, the economy's dependence on transport,
coupled with increased imports as UKCS production declines, reinforces
the need to improve the energy efficiency of oil-driven vehicles.
Prospective advances in vehicle technology hold out the possibility
of significant reductions in fuel use.
The potential long-term requirement for significant
CO2 emissions reductions from the transport sector
combined with the possibility that oil will become scarcer, raise
the need to develop alternative fuels. There is the long-term
prospect that the technology for powering vehicles by fuel cells
fed on hydrogen will fulfil its current promise, and so ultimately
provide a substitute for oil. Other options, such as liquid biofuels
may also have a role. International efforts are needed to develop
Handling the projected growth in aviation energy
use and CO2 emissions must become a priority. Taxation
and other measures to manage aviation demand should be prioritised
for discussion in EU and other international forums."
Of course, it may well be the case that including
aviation emissions in the EU ETS is seen by the UK Government
as a demand management policy tool. It doesn't seem to have any
impact on demand or speed up any supply-side efficiency gains
above and beyond those already forecast, as we have covered previouslyso,
reluctantly we must inform the Committee that as far as we are
concerned, there is no coherent DfT strategy for the stabilisation
and reduction of air transport's carbon-related emissions.
We have a more straightforward view of how demand
management should be applied to reduce air transport's climate
change-inducing emissions by adding, as various EU legislation
and polices already indicate should happen, the presently unaccounted
for external costs of air transport's social and environmental
impacts directly to ticket prices.
The range of aviation's environmental impacts
can be identified. These are: climate change; local air quality
and noise; health impacts; safety (accidents/third party risk);
land take; habitat (bio-diversity), heritage and tranquillity
losses; property devaluation; congestion; and an element of up/downstream
processes. It is possible to arrive at reasonable cost estimates
of these impacts. The best study we have found that tries to comprehensively
assess these factors and apportion costs accordingly is the INFRAS/IWW
study "External Costs of Transport", Update study, October
2004. This can be located at http://www.cer.be/files/INFRAS%20StudyEN-144344A.pdf
The INFRAS/IWW estimate for the external costs
of UK air transport presently unaccounted for and unpaid, is about
52.5 euros (£36) per 1,000 passenger kilometres or 3.6 pence
per kilometre. So, for instance, on a return flight from Luton
to Glasgow each passenger should pay an additional £36 for
the external costs of their environmental impacts. We believe
these figures may be on the low side.
The AEF published in June 2005, a comprehensive
commentary on air transport's impacts and market-based demand
management options in a pamphlet, "Fly now, grieve later"
by Brendon Sewill, at:
Whether externalities are internalised or aviation
is taxed just like any other business, the most important starting
point is to set environmental limits within which the air transport
sector must operate and develop a menu of policy options to achieve
those targets. Large decreases in aviation's impacts can only
be achieved by a combination of methods including increases in
ticket prices to dampen demand.
Brendon Sewill's analysis pointed to a figure
of £9 billion as a fair and equitable figure for the air
transport industry to pay in line with the "polluter pays"
principle. This figure is arrived at from assessing the broad
range of external costs that could reasonably be attributed to
UK flights as being between £6-£12.5 billion annually.
£9 billion is the figure that should be paid if air transport
was taxed at the same rate as car travel.
Adding an environmental tax at this level would
mean demand cut in half from 4% to 2% annually, leading to around
315 million passengers in 2030 instead of 500 million, a growth
rate that just might be within the scope of technological and
operational improvements. It would also mean, contrary to the
ATWP that no new runways were needed in the UK. A detailed analysis
of the way the final aviation ETS impacts on carbon reduction
policies will be necessary. The AEF intends to take this work
forward and update it once the EC aviation and the EU ETS policy
is outlined later this year.
There is scope for air transport's climate change
impacts to be reduced by implementing the AEF's plausible taxation
policy over say a 5-10 year period. Starting soon would mean that
a slowdown in growth could be underway by 2010 and well on course
by 2020. This is our response to the "what could the
DfT realistically do" question the Committee posed.
(a) Although today, non-carbon dioxide emissions
are thought to increase the total climate warming impact of aviation
by between two and four times that of the carbon dioxide alone,
this factor will change over timemost likely reducing.
The reason is that the carbon dioxide proportion of the emissions
will become more and more dominant as it lasts for over 100 years,
whereas contrails and cirrus produced today will be gone by tomorrow.
Therefore, if one were to imagine theoretically that aviation
growth fell to zero tomorrow, then although there will be the
same number of contrails and cirrus clouds produced tomorrow as
there were today, the CO2 in the atmosphere generated
by the aviation industry will be higher, despite zero growth,
as it adds to the CO2 that is already there. Therefore
the proportion of the total warming impact of aviation generated
by CO2 has increased, and that follows that the proportion
from non-CO2 emissions has decreased, ie the uplift
factor would be smaller tomorrow than it is today.
(b) The plot above does not take the basket
of six greenhouse gases into account, therefore uplifting the
aviation emissions in this way requires that all other sector's
emissions should also be uplifted to account for their other gaseous
1 DfT 2004: Aviation and Global Warming, Department
for Transport, London. Back
See: Stordal F, Myhre G, Arlander D W, Svendby T, Stordal E J
G, Rossow W B and Lee, D S, 2005: Is there a trend in cirrus cloud
cover due to aircraft traffic? Atmospheric Chemistry and Physics
5, 2155-2162. and Zerefos, CS, Eleftheratos, K, Balis, DS, Zanis,
P, Tselioudis, G, and Meleti, C, 2003: Evidence of impact of aviation
on cirrus cloud formation. Atmospheric Chemistry and Physics 3,
Sausen R, Isaksen I, Grewe V, Hauglustaine D, Lee D S, Myhre
G, Khler M O, Pitari G, Schumann U, Stordal F and Zerefos C, 2005:
Aviation radiative forcing in 2000: and update on IPCC (1999).
Meteorologische Zeitschrift 114, 555-561. Back
This may not be strictly scientific for the following two key