Memorandum submitted by the Aviation Environment
Federation (CCB 08)
The Aviation Environment Federation (AEF) welcomes
the opportunity to respond to the EFRA Committee enquiry scrutinising
the Draft Climate Change Bill. AEF is the UK's only national NGO
working exclusively on controlling and reducing the environmental
impacts of aviation, and as such we will confine our response
to one of the Committee's questions which is relevant to the sector.
EXECUTIVE SUMMARY
The Committee has asked for comment on "the
validity of the Government's domestic targets to reduce CO2
emissions by 60% below 1990 baseline levels by 2050" (Question
1). We have two points to make in relation to the 60% target.
Firstly, the headline target of a 60% cut in
carbon emissions should be strengthened to an 80% cut in accordance
with the latest recommendations of climate scientists.
Secondly, both 2020 and 2050 targets should
include emissions from international aviation and shipping from
the outset. These should be calculated according to IPCC guidelines
for reporting emissions from international bunker fuels—something
the UK already does, since it is obliged under the Kyoto Protocol
to report these emissions as a Memo Item to its national Greenhouse
Gas Inventory.
1. In common with over 50 environment, development
and faith groups that form the Stop Climate Chaos coalition, we
are calling on the Government to adopt a target of at least an
80% cut in CO2 emissions below the 1990 baseline.
1.1 This would represent the UK's equitable
share towards stabilisation of atmospheric CO2 at 450
ppmv, which the latest climate science indicates is necessary
to yield a reasonable chance of limiting global surface temperature
rise to 2°C—the declared objective of the UK, the EU
and the UN. The target should be subject to review by the Committee
on Climate Change as the science develops.
1.2 We will not labour this point as we
anticipate that other environmental groups will deal with it in
much greater detail.
2. Whatever cut is adopted in the Bill,
it cannot be regarded as valid if it excludes emissions from international
aviation and shipping.[1]
2.1 The scale of the problem
2.1.1 Aviation is the fastest-growing source
of greenhouse gas emissions in the UK. Without action to tackle
emissions, the sector is on course to use up a significant fraction
of the UK's entire carbon budget. Even the Department for Transport's
own projections show that aviation will emit 17.4 million tonnes
of carbon (MtC) in 2050, equivalent to 26% of the UK total carbon
allowance under a 60% cut. Two other projections, by the Tyndall
Centre for Climate Change Research and by Owen and Lee for Defra[2]
put the figures rather higher. (Under an 80% cut, each of these
percentages would of course be doubled.)
|
| 60% cut
| 80% cut |
|
| DfT | 26% |
52% |
| Owen and Lee | 44%
| 88% |
| Tyndall | 48%
| 97% |
|
Aviation's share of overall UK emissions under a range
of scenarios
(The lower estimates of Owen and Lee have been used; furthermore
their figures are for scheduled traffic only and therefore under
estimates.)
2.1.2 Self-evidently, no target can be regarded as valid
if it ignores such a significant source of emissions.[3]
2.2 The Bill as it stands
2.2.1 The Draft Climate Change Bill excludes emissions
from international aviation and shipping from the 2020 and 2050
targets, on the grounds that there is no international agreement
on how to allocate these emissions to individual states.
2.2.2 Section 15 Clause (3) makes provision for
including these emissions "if there is a change in international
carbon reporting practice". In the Consultation Document
accompanying the Draft Bill, this is enlarged upon: "for
example, if emissions from international aviation and/or shipping
are included in emissions reductions targets in the future."[4]
2.2.3 Furthermore, Section 15 Clauses (4) and (5)
make provision for including such emissions using a different
base year and "provide for the emissions in that year...
to be taken into account as if part of the 1990 baseline."
2.2.4 In other words, it is envisaged that as and
when international agreement is reached on aviation and/or shipping
emissions, the overall target will be relaxed in order to accommodate
them.
2.3 Problems with this approach
2.3.1 In AEF's opinion reaching an agreement is
a distant prospect: both methodological and highly sensitive political
issues remain to be resolved, and while Europe continues to press
for the resumption of talks at the UNFCCC's Subsidiary Body for
Scientific and Technical Advice (SBSTA), certain states (notably
Saudi Arabia), remain uncooperative. Without consensus, international
progress in this forum is effectively blocked.
2.3.2 Nor would aviation's inclusion within the
EU ETS necessarily constitute "a change in international
carbon reporting practice", for the following reasons:
— the proposed scheme would cover all flights
arriving and departing the UK—not an allocation option proposed
by SBSTA, nor one that any government would accept for its own
targets, since if it were adopted globally there would be double
counting;
— the European Commission will only work out
Member States' emissions for the purposes of allocating permits,
ie their emissions in the baseline year (currently an average
of 2004-06 is proposed). Emissions for years when the scheme is
operating will be reported by individual airlines, the entities
required to surrender permits. With centralised allocation there
will be no equivalent of a state-level NAP and emissions will
not necessarily be aggregated at Member State level;
— emissions may well only be reported over
five-year trading periods, rather than for each calendar year.
2.3.3 So the inclusion of international aviation
emissions within the UKs targets cannot be regarded as "just
around the corner". International agreement could well be
a decade away. International aviation already accounts for 5.9%
of the UK's carbon emissions and the industry is growing rapidly:
the later emissions are included, the greater the shock to the
system; or, the more the target will have to be diluted to accommodate
them.
2.3.4 The emissions pathways set out in the Climate
Change Bill are calculated to achieve a given CO2 stabilisation
target. Just as the stabilisation aim cannot be achieved with
one source of emissions excluded, it cannot be achieved with that
source included on a different, laxer basis. The crucial factor
in tackling climate change is not simply arriving at a given reduction
target but the cumulative stock of greenhouse gases in the atmosphere.
The Bill's proposed trajectory would therefore be invalidated
if aviation emissions were incorporated into the 2020 and 2050
targets at a higher level than emissions from other sectors.
2.3.5 Alterations to the UK's climate targets also
undermine the certainty that investors require when taking long-term
decisions; this is particularly the case in an industry such as
aviation where capital stock is expensive and long-lived.
2.4 An alternative approach
2.4.1 Although there is little prospect of international
consensus on allocation for the purposes of binding targets
in the short-term, the Intergovernmental Panel on Climate Change
publishes internationally-accepted guidelines to States on how
to report emissions from international bunker fuels. The UK is
required to submit this information as a memo item to UNFCCC along
with our annual GHG inventory, and accordingly the Government
has for several years compiled and reported official figures for
emissions from international aviation.[5]
2.4.2 The official Netcen figures go back to 1990
and so could be used to include aviation emissions on the same
basis as other sectors from the moment the Bill becomes law.
2.4.1 It could be argued that the practices set
out in these guidelines do already constitute "international
carbon reporting practice". The term is defined in Section
38 of the Draft Bill as "accepted practice in relation to
reporting for the purposes of the protocols to the United Nations
Framework Convention on Climate Change", and one such purpose
is "the limitation or reduction of emissions of greenhouse
gases... from aviation and marine bunker fuels".[6]
In this case, emissions from international bunker fuels do not
constitute a special case at all, and the whole of section 15
of the Draft Bill could be deleted. Targets could then be modified
to accommodate changes in international policy under the provisions
set out for other sectors in Section 3 Clauses (3) and (4).
2.4.4 Alternatively, it could be argued that for
the purposes of a domestic target, the UK does not need international
consensus. In this case, Section 15 should be amended, requiring
the Secretary of State to make special provisions for aviation
and shipping straightaway, in accordance with IPCC guidelines.
Any flexibility as to the baseline year should be removed, but
some flexibility should be retained to alter these provisions
should international policy change.
2.4.5 Whichever method is adopted, the recalculation
of targets and realignment of emissions pathways necessary when
international consensus is finally reached is likely to be an
order of magnitude smaller than if aviation were then included
for the first time. In addition to the obvious environmental advantages,
there would be greater certainty for businesses and investors,
who are less likely to over-invest in carbon-intensive infrastructure
if clear long-term signals are given from the outset.
Aviation Environment Federation
May 2007
1
As a specialist aviation organisation, our comments will focus
on this sector. Our NGO colleagues with an interest in maritime
environmental issues report that emissions from international
shipping, could and should, be treated in the same way. Back
2
http://www.eci.ox.ac.uk/research/energy/downloads/predictanddecide.pdf,
table 2.4, page 15. Back
3
These figures take no account of the non-CO2 effects of aviation,
which increase its total impact on the climate by between two
and four times, according to the IPCCs 1999 report Aviation
and the Global Atmosphere. Some uncertainty remains over the
exact quantification of these effects, and so for as long as the
Bill in general only accounts for CO2 and not other Kyoto gases,
for consistency we accept the rationale for the non-CO2 effects
of aviation to be excluded. These effects do, however, significantly
increase the urgency of bringing aviation within a framework for
tackling climate change. Back
4
Note 29 to para 5.23. Back
5
Historical emissions back to 1990 are reported by Netcen for
the UK GHG inventory on the basis of fuel uplifted in the UK.
Since 2006, IPCC guidelines have offered states the possibility
of estimating emissions on a route-by-route basis, the so-called
Tier 3 methodology. It is as yet unclear whether Defra has instructed
Netcen to use this method. The DfT accepts emissions calculated
from fuel sales as a good approximation for emissions from all
flights departing the UK, treating the historical data and its
own forecasts (based on all departing flights) as a seamless whole. Back
6
Kyoto Protocol to the United Nations Framework Convention on
Climate Change, Article 2.2. Back
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