Memorandum submitted by the Royal Society
for the Protection of Birds
The RSPB is Europe's largest wildlife charity
with over one million members. We manage one of the largest conservation
estates in the UK with 188 nature reserves, covering more than
127,000 hectares. The RSPB is part of the BirdLife International
partnership, a global alliance of independent national conservation
organisations working in more than 100 countries worldwide.
We consider that human-induced climate change
poses the biggest long-term threat to global biodiversity. A recent
paper in Nature by a large group of scientists (including
one from the RSPB) indicates that in sample regions covering about
20% of the Earth's land surface "15 to 37% of species in
our sample of regions and taxa will be `committed to extinction'
as a result of mid-range climate warming scenarios for 2050."
To avoid such a catastrophe, the anthropogenic
greenhouse gas emissions that cause climate change need to be
cut hard and rapidly. We therefore support policies and measures
that do so, particularly those that tackle transport-related emissions
which are consistently the fastest growing source of emissions
and may well be the UK's largest source by 2020.
Indeed, in terms of carbon dioxide emissions by end-user, transport
emissions are already on a par with industry and the domestic
sector, see the figure below.
Whilst we welcome the DfT taking on a Public
Service Agreement to reduce carbon dioxide emissions (as had previously
urged them to do) we remain sceptical about UK transport emissions
declining sufficiently to meet the DfT's targets without very
significant strengthening of the current suite of UK transport
policies and the addition of further policies and measures. Indeed,
we consider that without urgent action on transport policy, the
UK is in danger of missing its national emission reduction targets.
In this response we focus primarily upon the
last of the five strategic issues that the Committee expressed
an interest in, ie "what specific steps the department should
now take to reduce road transport carbon emissions and congestion
over the next decade?" At the end, we provide some observations
on what we feel needs to be done to constrain growth in aviation
emissions, which are of particular concern.
2. ROAD TRANSPORT
If we are to stand any chance of achieving our
20% carbon dioxide emission reduction target, we need at least
to halt and preferably reverse the current increase in transport-related
emissions, which means that existing measures need to be strengthened
considerably and some new ones introduced. In the first part of
this section, we consider how to strengthen and add to existing,
mostly fiscal, road transport measures. In the second part, we
examine other means of cutting emissions, such as by shifts between
2.1 Strengthening and adding to existing measures
The voluntary agreements with EU, Japanese and
The EU car manufacturers have conceded that
the voluntary agreements are not working as effectively as they
had predicted. We doubt that they will deliver the target of a
fleet average of 140g/km across the EU by 2008-09.
There thus appears to be a good argument for extending and significantly
strengthening the agreements and probably making the agreements
mandatory. Whilst there may appear to be difficulties associated
with having mandatory agreements with non-EU companies, there
are ways around them. California has, for example, been highly
successful in persuading foreign companies to comply with its
domestic legislation on vehicle emissions, largely because it
is a very big market, as is the EU. By adopting mandatory targets,
the EU could not only reduce its own emissions but have an additional
We consider that there is a need for a mandatory
upper limit on emissions from new cars. An initial aim for 2010
might be 250 g/km. An upper limit would force the fleet average
downwards and prevent the manufacture of wasteful vehicles.
The agreements, voluntary or mandatory, should
be extended to all road vehicles, including lorries, again with
overall, mandatory emission limits on new vehicles.
To make mandatory targets both politically acceptable,
and achievable at lowest cost, it might be possible to consider
introducing the flexibility of trading, either within the automotive
sector itself or, more probably, by opting the sector into the
EU ETS, at some point after the end of the second period.
The high rate of taxation on vehicle fuels has
had a significant effect on the types of vehicles that people
use, and we regret the dropping of the fuel duty escalator which
sent a clear signal that prices were to continue to rise.
However, taxes on fuel are not generally seen
as an environmental measure and the way in which they are perceived
has not been helped by some tax breaks which, however well-intentioned,
are not clearly good for the climate change, such as the lower
excise duty on LPG. In our opinion, this situation could be rectified
by the replacement of existing fuel taxes by a straightforward
carbon tax (applied in proportion to the well-to-tank carbon emissions
of the fuel) or cap and trade scheme, which we discuss later in
this document. At the very least, fuel duty differentials and
rebates should be increased to reflect differences in well-to-tank
Vehicle Excise Duty and company car tax
We consider that basing VED and company car
tax on carbon emissions is a good idea. We would, however, significantly
increase both differential between tax bands and considerably
increase the duty payable in higher, more polluting bands, perhaps
reducing VED on cars under 100 g/km to zero. We would also suggest
harmonising VED bands with the A-F bands under the new voluntary
car labelling scheme, and increasing the number of bands used
for the label, specifically by dividing the most polluting band,
band F, into at least two. At present, extremely inefficient vehicles
are treated on a par with less inefficient ones.
Some have argued that these kinds of taxes are
ineffective because they represent only a small proportion of
the costs of buying and running cars. However, not only do they
send a clear signal that greenhouse gases will be increasingly
costly to emit but they force car buyers to be aware of the emissions
from their vehicles, because advertising literature cites, and
now labels, emissions. There is thus a good reason for retaining
and strengthening the taxes, if only for public information reasons.
This is especially true since the launch last year of the UK voluntary
To reinforce the tax signals provided by carbon-based
fuel duty and carbon-related VED, both of which operate after
the point of purchase, it would be very sensible to introduce
a feebate system that operated at, and therefore influenced, the
point of purchase itself. Feebates would use revenue from purchase
charges on polluting vehicles to provide capital grants for efficient
vehicles. The overall effect would be revenue neutral, and socially
progressive. The Feebate scale could be based on the labelling
bands, with the middle band attracting neither a charge nor a
Congestion/road user charging
The RSPB has long supported congestion charging
and, to a lesser extent, road user charging because they help
to reduce vehicle emissions. However, because they do not directly
target emissions, they are not an instrument that can be relied
upon to, alone, deliver substantial emission reductions. Indeed,
we are generally in agreement with the Government's road pricing
feasibility study which came to much the same conclusion.
Whilst the RSPB is supportive of the increased
use of biofuels for the reduction of greenhouse gas emissions,
we have biodiversity-related concerns about the potential scale,
type and location of the energy crops from which they are derived.
If farmed intensively, on a large scale and in the "wrong"
places, such crops could have a considerable, adverse effect upon
wildlife, both at home and abroad. We therefore favour an approach
that includes spatial planning to determine the appropriate scale
and location for development, as well as strategic environmental
assessment of any programmes that are proposed (following the
example of offshore wind). Individual biomass or biofuel processing
plant would also be subject to environmental impact assessment.
In addition, an accreditation scheme should be established for
the growth of energy crops, detailed in our responses to the DfT
consultation on a biofuels strategy and the Defra consultation
on the strategy for non-food crops uses which are available on
request. This accreditation scheme would consider both the life-cycle
carbon balance of the biofuel source, and its other impacts on
the environment, including biodiversity.
If biofuels are to be used extensively, they
will require government support. We consider that a biofuels obligation
of the type currently being developed by government, as a result
of the Biofuels Directive, is probably not the best approach.
A more general approach that encourages the broad development
of any type of low or zero carbon fuel would be better and would
not "pick winners" in the way that a biofuels obligation
would. We prefer a well-to-wheel carbon tax or a cap and trade
scheme, which we discuss in the next section.
A well-to-wheel carbon tax
A UK, or preferably EU-wide, carbon tax on vehicle
fuels, replacing all existing duties on fuel, would be a valuable
addition to the current portfolio of measures for reducing emissions
from road transport. A so-called well-to-wheel (or more accurately,
well-to-tank) duty levied in direct proportion to the carbon content
of fuel, including carbon arising from its extraction, refining
and distribution, would clearly target the problem of climate
change whilst also encompassing a wide range of fuels and technologies,
including biofuels and hydrogen. It would be a fair tax, penalising
the use of polluting fuels but not clean ones.
To be practical, a well to wheel tax would have
work on average emissions from certain activities and would probably
need to avoid double counting emissions from some of them. However,
we can see no major technical obstacles to its introduction. As
an interim measure, fuel duty differentials could be considerably
increased and more finely graduated to reflect life-cycle carbon
emissions. This instrument could be made revenue neutral.
Alternatively, a cap and trade scheme could
be applied to the road transport sector, probably initially in
the UK. Because of the large number of individual sources of emissions,
it would be administratively sensible for the allocation to be
made upstream, at oil depots where the fuel comes out of bond.
Having an upstream allocation would mean that it would have to
be made on the carbon content of the fuel. Initially, such a scheme
would probably need to be run separately from the EU one, but
could eventually be integrated with the ETS. The scheme would
replace existing fuel taxes. Alternatively, the obligation could
be placed on car manufacturers, based on fleet averages.
2.2 Other means of cutting emissions
The role of industry in developing and implementing
low carbon vehicle and fuel technologies
The technology already exists to mass produce
cars, such as petrol hybrids, that have significantly lower carbon
emissions. The key is, therefore, to overcome the barriers to
the sale of such vehicles.
Much more must be done to inform people of the
environmental effects of transport use. The voluntary car label,
developed by the Low Carbon Vehicle Partnership, is a start. Although
the label is a voluntary scheme, the Government should push for
it to be made mandatory across the EU, and to include efficiency
information on all vehicle adverts.
The cost of low emissions vehicles is an obstacle
to their uptake. The Government must continue to review the effectiveness
of the Transport Energy grants to ensure they are acting as a
catalyst for real changes in the UK vehicle fleet.
Getting the best out of our transport system
In recent years, the emphasis of Government
road transport policy has been on getting the best out of the
transport system by tackling congestion. However, the RSPB considers
that this emphasis should change to reducing the amount of greenhouse
gas emissions from road transport. In order to achieve this, Government
transport policy must refocus on achieving modal shift and reducing
the need to travel. (Achieving modal shift is discussed further
in the next section.)
Reducing the need to travel does not necessarily
mean restricting the movement of people and goods. It means that
people should be provided with the opportunity to go about their
lives without having to travel ever increasing distances. This
can be achieved by utilising effective planning policies and by
the use of information technology.
With regards to planning, there are a number
of measures which can be introduced:
tighten planning standards and guidance
to ensure that new commercial and residential development is high
density with low levels of parking and designed to maximise walking
retain and strengthen controls on
out of town retail and business parks;
ensure new residential development
has a wide range of local community facilities and services within
walking or cycling distance to reduce the need to travel. Protect/fund
key local facilities such as shops, post offices, banks etc.
As a minimum, all of these measures should be
integrated into the Government's plans for sustainable communities.
Information technology must be part of the solution
to reducing carbon emissions from transport. The use of broadband
can make home working and shopping much easier. The Government
should work with the telecommunications industry to increase the
coverage of broadband and to reduce the costs.
How to encourage and help people to make smarter
choices about the way they travel
In order to make smarter choices about the way
they travel, people must be provided with a viable alternative
to the car. Government must, therefore, increase funding of public
transport systems to increase frequency and reliability of services
and to reduce the cost of travelling.
However, there is a range of other measures
that can be introduced to encourage people to utilise more sustainable
modes of transport. These range from fiscal measures, such as,
well-to-wheel fuel tax, road-user charging and workplace parking
levies, through to "softer" measures, some of which
are described below.
Workplace and school travel plans can play an
important role in reducing the traffic generated by specific organisations
and schools. The Government should make it a requirement for all
schools with over 100 pupils and organisations with over 200 employees
to develop travel plans.
The planning system can also help to encourage
people to make smarter choices by designing new developments with
good public transport links and by supporting car clubs with reserved
parking; implementing them as a standard feature of new residential
Provision of information can also be important
in highlighting alternatives to car travel. The Government's Transport
Direct project could be a useful tool, although it has had its
initial teething problems. This project should be built upon to
develop a transport information database that can be relied on
by the public and businesses.
Although aviation emissions are a quite small
fraction of total UK emissions at about 5.7%, they are by far
the fastest growing source of emissions, at about 6% per year
between 1993 and 2003, despite a slight fall in 2001.
EU aviation emissions are increasing at a similar rate (about
5.6% per annum) and as the European Commission points out "If
the growth continues as up to now, emissions from international
flights from EU airports will by 2012 have increased by 150% since
1990. This growth in the EU's international aviation emissions
would offset more than a quarter of the reductions required by
the Community's target under the Kyoto Protocol."
UK air traffic forecasts (DfT 2000 currently
being revised) indicate that passenger numbers will more than
double over the next 20 years, from 160 million in 1998 to 400
million in 2020 (mid-range forecast). The EU Commission forecasts
that emissions from aviation will triple by 2020 from 1990 levels
to between 6 and 8% of all EU emissions. Other forecasts in general
terms support the UK and EU's figures, for example the International
Civil Aviation Organisation (ICAO) estimates that the global fleet
of aircraft will double from 12,300 to 25,000 between 2002 and
Some projected estimates of future fuel use are given below.
in early 90s
used in 2015
used in 2050
|AERO (excl military)||134.2
||166.0 (1997)||257.8 (2010)
Any such rates of growth are clear unsustainable in a world
that should be curbing its greenhouse gas emissions, especially
because the effect of aviation emissions taken together is greater
than for carbon dioxide alone. In 1999 the Intergovernmental Panel
on Climate Change (IPCC) estimated that the total impact of aviation
emissions on the atmosphere was between two and four times that
of carbon dioxide alone.
Cutting Aviation Emissions
There are two main ways of cutting aviation emissions: technical
improvements to aircraft (and to a lesser extent improvement to
their flight paths) and limiting demand. Although the fuel efficiency
of aircraft has constantly improved, these improvements have been
more than cancelled out by huge increases in demand. As mentioned
above, all reputable forecasts envisage this trend as continuing
and so measures that limit demand for aviations are essential,
even in a world of rising fuel prices. (Fuel prices are quite
a small proportion of aviation costs, at most 25%, according to
One obvious way of limiting emissions from aviation is by
a fuel tax but this is unlikely to materialise in the foreseeable
future. In part, this is because aviation is an international
business and its emissions really need to be tackled globally,
yet international taxes are hard to agree and impose, and the
same would be true of a worldwide set of harmonised national taxes.
Also, and probably more importantly, emissions from international
travel come under the remit of the International Maritime Organisation
(IMO) for shipping and the ICAO for aviation, rather than the
Convention on Climate Change and its Kyoto Protocol as is the
case of all other emissions. ICAO was established by the 1944
Chicago Convention which, together with a host of bilateral air
service agreements, excludes taxes on fuel used for international
flights, although domestic taxes are allowed and some countries,
notably the USA, have such taxes. Without amending both the Chicago
Convention and all of the bilateral agreements, a fuel tax is
not legally possible and such amendments would take decades. An
EU aviation fuel tax has been mooted but EU member states are
signatories to the Chicago Convention and have their own bilateral
air service agreements. The RSPB has long argued that aviation
emissions should come under the remit of the Climate Convention,
rather than ICAO, but this change in competence is, again, unlikely
because a number of countries have long opposed such a move, particularly
Three main alternatives to aviation taxes exist: a standing
charge (such as the UK's Air Passenger Duty), an emissions or
route charge, or including aviation emissions in a cap and trade
scheme. Standing charges could work and are a desirable first
step. But, to be perceived as a fair means of limiting climate
change, they would need to levied at least roughly in proportion
to the damage that any particular flight causes and so would need
to be highly differentiated on the basis of emissions per flight.
Also, it is unlikely that charges would be levied at a level that
reflects the damage caused by aviation or even at a level that
would put aviation on a par with other transport modes. For example,
if a charge were to be applied at the same rate as petrol is taxed,
the levy on a flight to Australia would be about £700. It
would be politically hard to charge this much. Also, it would
be difficult to coordinate any charge internationally although
it would be possible within the EU.
Emissions or route charges can work and have been applied
(for NOx emissions) at Zurich Airport and in Sweden. Again, however,
it would be difficult to apply a worldwide emissions charge or
a harmonised set of national ones, although an EU-wide charge
would be feasible. A practical, and potentially a legal difficulty
with emissions charges is, however, that they would have to be
linked to fuel consumption and a charge would thus look like a
fuel tax. The Swedish charge met with this problem, when the other
Scandinavian countries challenged its legality on the grounds
that it was really a fuel tax.
The last main option is to have a cap and trade scheme for
aviation. Like an emissions charge, this has the advantage that
the concept had not been thought of in 1944 and is thus not prohibited
by the Chicago Convention and, moreover, it is clearly not a tax.
Ideally, were aviation emissions to be included under the remit
of Kyoto, then they would be capped by the Kyoto targets and could
be traded under its global emission trading scheme. Indeed, even
ICAO concluded that what they called an "open" emissions
trading scheme would be the best way of coping with aviation emissions.
(By "open", ICAO's Committee on Aviation Environmental
Protection meant a system in which aviation emissions would be
traded with emissions form other sources. The only global system
of this type is the Kyoto one.)
It seems unlikely that the type of system envisage by ICAO
will occur in the foreseeable future but the European Commission
has concluded that the best option for limiting EU demand for
aviation would be to opt EU aviation emissions into the EU Emissions
Trading Scheme (EU ETS).
The UK and France support this proposal. The RSPB also welcomed
the Commission Communication on the subject and we sit n the Commission
working group considering the subject in more detail.
However, before a Directive opting aviation into the EU ETS
can be produced, a number of key issues need to be resolved. The
first of these is the scope of the scheme: should only flights
between EU countries be included or should all flights to and
from the EU be included as well? We consider that it is essential
that all flights should be covered, not only because this is clearly
the best option environmentally but also because partial coverage
could potentially distort the aviation market. If only intra-EU
flights were included then not only would a mere 32% of emissions
be captured but airlines that operated both within and outside
the EU could cross subsidise internal flights from external ones,
as the low cost airlines have pointed out.
The second main issue that a Directive needs to address is
the non-carbon dioxide impacts of aviation emissions. Aircraft
have a number of effects on the atmosphere that when added together,
have two to four times effect of carbon dioxide alone.
To capture these additional impacts in any climate change-related
measure is clearly important. There are potentially three ways
of doing so: (i) via the use of a multiplication factor on carbon
dioxide, (ii) an effect by effect approach to account for CO2
and non-CO2 effects over time when they are more perfectly
understood and (iii) a CO2 only emissions trading scheme
and potential ancillary instruments for non-CO2 effects.
Our view is that the best option would be a multiplier because
the other two options would almost certainly lead to long delays
Thirdly, a question arises as to how to allocate emission
allowances, and at what level; are they to be allocated free of
charge by member states, as for all other EU ETS allowances or
should another method be employed? Linked to this question is
another one, which is who decides on the allocation: member states,
the Commission or another body? We consider that the simplest,
and most environmentally effective way to resolve both questions
would be for allowances to be auctioned. Auctioning would also
address two further difficulties: firstly, that a Directive will
probably come into force well into the second phase of the EU
ETS (when all other allocations will have been agreed and given
out) and, secondly, the fact that allowances will be worth more
to the aviation industry than to the rest of the traded sector.
An auction will at least help address these difficulties.
Chris D Thomas et al, Extinction risk from climate change,
Nature, 8 January 2004. Back
Updated Emissions Projections: Final Projections To Inform The
National Allocation Plan (NAP), DTI, 11 November 2004. Back
After making good progress in early years, progress has slowed.
ACEA data indicates that European car makers achieved only a 0.6%
decrease in new car emissions in 2003, about the same as in 2002.
The industry will now have to achieve annual 2.8% cuts every year
from 2004 to meet the target. At this rate, the 140g target will
be missed by at least 20%. Back
Table 3.8 page 54 of Transport Statistics Great Britain 2005
Edition, TSO, DfT 2005. Here the figures used are for civil (domestic)
aviation and international aviation combined, as opposed to the
more commonly used international aviation figures. Back
Commission communication "Reducing the Climate Change Impact
of Aviation" 27.9.2005 COM (2005) 459 final. Back
Report of the Sixth Meeting of ICAO's Committee on Aviation Environmental
Protection, 2 February 2004. 1.1.4. Back
"Study on air quality impacts of non-LTO emissions from
aviation", Norwegian Meteorological Institute 2004). Back
Aviation and the global atmosphere, JE Penner, DH Lister,
DJ Griggs, DJ Dokken, M McFarland (Eds). Cambridge University
Press, UK. pp 373, 1999. Back
This and all other options for limiting demand are included in
the Commission Staff Working Document, Annex to the Communication
from the Commission "Reducing the Climate Change Impact of
Aviation", Impact Assessment [COM (2005) 459 final]. Back
Commission communication "Reducing the Climate Change Impact
of Aviation" 27.9.2005 COM (2005) 459 final. Back
IPCC special report on aviation and the global atmosphere, Cambridge
University Press, 1999. Back