Memorandum submitted by Sustainable Aviation
1. INTRODUCTION
1.1 Sustainable Aviation (SA) is a long term
strategy which sets out the collective approach of UK aviation
to tackling the challenge of ensuring a sustainable future for
our industry. A world-first, Sustainable Aviation was launched
in 2005 and brings together the UK's leading airlines, airports,
aerospace manufacturers and air navigation service providers.
1.2 Signatories to the SA Strategy are committed
to delivering significant reductions in the UK aviation industry's
carbon dioxide emissions, nitrogen oxide emissions and aircraft
noise over the next 40 years and beyond.
1.3 SA establishes mechanisms for monitoring
and regular reporting of progress towards a range of specific
objectives. Our Strategy sets out the industry's vision for a
sustainable future through a series of seven goals and 30 commitments,
relating to economic, environmental and social aspects of aviation.
Specifically in relation to climate change, these include:
— Limiting climate change impact by improving
fuel efficiency and CO2 emissions for new aircraft
by 50% per seat kilometre by 2020 compared with 2000 levels.
— Reducing nitrogen oxide (NOx) emissions
by 80% over the same period.
— Establishing a common system for the
reporting of total CO2 emissions and fleet fuel efficiency,
and pressing for aviation's inclusion in the EU emissions trading
scheme at the earliest possible date.
1.5 We have established a governance structure
to ensure implementation and communication of the Strategy. This
comprises a pan-industry, high-level Sustainable Aviation Council
and a Working Group, supported by a series of sub-groups.
1.6 Signatories to Sustainable Aviation include:
Airlines: British Air Transport Association (BATA);
British Airways; bmi; Virgin Atlantic; FlyBe; Monarch; easyJet;
Thomas Cook; Thomson Airways
Airports: Airport Operators Association (AOA);
BAA; Manchester Airports Group (MAG), Newcastle, Birmingham International,
Peel Group, Belfast City, Leeds Bradford, London City, Infratil
Airports, Bristol International
Manufacturers: Society of British Aerospace Companies
(SBAC); Airbus; BAe Systems; Cobham; Doncasters; FAC; GKN; Marshall
Aerospace; Messier Dowty; QinetiQ; Rolls-Royce; Bombardier
Air Navigation Service Provider: NATS
1.7 We published our first Progress Report
in 2006, and a second in 2009 (the Executive Summary is attached
at Section 9) and will continue to deliver on the goals and commitments
identified in the strategy, as well as promoting our work both
within the UK and internationally.
1.8 Sustainable Aviation supports the initiatives
being taken at a global level by the aviation industry, most recently
illustrated by the proposals at the UN Climate Change Summit in
New York on 22 September.
1.9 We also include at Section 9 a copy
of the letter we have written to the Secretaries of State for
Transport, and Energy & Climate Change, in response to the
Committee on Climate Change's letter of 9 September 2009. We believe
our response forms the basis for a pragmatic manifesto for real
progress to be made at the Copenhagen climate summit in December.
2. SUMMARY
2.1 SA's submission to the Committee responds
to the specific questions posed. We then explore more fully the
developments to which the UK aviation industry is committed and
we are happy to have the opportunity to provide further explanation
to the Committee in October. In brief, we would like to highlight
the following points:
— Aviation is a global industry and solutions
to the industry's environmental impact must be secured at international/global
level.
— CO2 emissions from international
aviation should be included in a post-Kyoto global climate change
agreement through a global sectoral approach, or deal, under which
they would be treated as an indivisible sector total and not apportioned
to individual States.
— Emerging technologies will achieve significant
longterm reductions in the environmental impact of flying.
— SA's Roadmap illustrates our confidence
that CO2 emissions can be curbed to 2000 levels by
2050 notwithstanding growth as forecast in passenger (and therefore
flight) numbers.
— SA manufacturing signatories continue
to invest heavily in research and development to improve fuel-efficiency
of new aircraft, and to reduce noise and emissions; SA airline
signatories continue to upgrade their fleets and streamline their
operations; SA airports are working collaboratively with the airline
and air traffic communities to develop and deliver ground-based
operational improvements to reduce emissions; and NATS, the UK's
air navigation service provider, is the first in the world to
have set targets to reduce air traffic management-related CO2.
— Collectively, the industry has committed
to meeting challenging targets for CO2, NOx and noise
set by ACARE. These targets are shared between improvements in
engine (15-20%), airframe (20-25%), operations and air traffic
management (5-10%). Putting a price on carbon within a cap and
trade system would ensure net emissions will not rise. However,
current levels of R&D investment by industry and government
are inconsistent with having sufficient, mature technology to
deliver against these demanding targets.
— Aviation is a great success story for
the UK and requires no funding from the public purse. The industry
is investing significantly in researching solutions to its environmental
impact, which should be both recognised and encouraged by Government.
3. RESPONSES TO
THE COMMITTEE'S
QUESTIONS
3.1 What opportunities exist for the creation
of a green new deal whilst pursuing a low carbon economy? Which
technologies have the greatest potential? Has the Government done
enough in its stimulus package?
3.1.1 Engine and airframe developments, together
with second-generation biofuels, offer the greatest long-term
potential for reducing aviation-related CO2. In the
shorter term, air traffic management offers environmental efficiencies
through new tools enabling improved procedures and more efficient
use of airspace. Airports are working with airlines, on-airport
businesses, and passengers to influence further carbon reductions;
for instance, on-site renewable energy, and fixed electrical ground
power (FEGP) to aircraft, which removes the need to run aircraft
power units whilst on the ground.
3.1.2 The Government's stimulus package must
recognise the importance of R&D in identifying opportunities
for a "green new deal" and provide incentives for long
term investment in R&D programmes.
3.2 How realistic are the Committee on Climate
Change's projections for the use of different types of new technologies?
What is needed to achieve the development and deployment of them?
3.2.1 The Committee's report on Aviation is
due to be published in December 2009. It will consider UK aviation
demand and emissions, improving the carbon efficiency of aircraft,
use of biofuels and hydrogen, and elements of a global deal.
3.2.2 We welcome the Committee's recognition
of the importance of carbon trading and the need for a global
sectoral deal for aviation. That global deal must encompass emissions
from all international aviation, to avoid competitive distortion,
avoid creating a patchwork of conflicting and potentially overlapping
national and regional policies, and avoid "carbon leakage".
3.2.3 The global deal should cover only the
CO2 emissions from aircraft, consistent with ICAO's
recommendation, recognising both the uncertainty in scientific
knowledge and the difficulties in characterising the non-CO2
climate effects of aircraft at altitude. Policy to address non-CO2
climate effects should be developed and implemented, separately,
when there is a clear scientific basis for doing so.
3.2.4 We also welcome the committees recognition
that a significant increase in investment in R&D will be required
if the targets are to be met.
3.3 What are the most important drivers, nationally
and internationally, for a low carbon economy in the UK? To what
extent do the outcomes of the international negotiations at Copenhagen
matter?
3.3.1 Aviation is a global industry with operating
standards set and coordinated internationally, through the International
Civil Aviation Organisation (ICAO). The UK is part of a global
network, contributing a significant percentage of aircraft into
the core of Europe, not only through local European traffic, but
also because of its unique position as Europe's primary North
Atlantic gateway. The efficient transfer of aircraft from one
country to another can fundamentally affect the capacity of the
system so it is vitally important that we work cross-border if
we are to achieve the synergies which will deliver environmental
benefit. The sustainable growth of aviation underpins the future
growth of the UK economy; maintaining our competitiveness is why
a global deal on aviation is so important.
3.3.2 It is fundamentally important to have
a globally agreed deal on aviation emissions; the current patchwork
of regionally based emissions schemes will lead to inappropriate
outcomes, notably carbon leakage.
3.3.3 The global deal should be based on global
targets, and full and open emissions trading; incentivise airlines
to purchase low-carbon aviation fuels that offer net carbon reductions
over their full life cycle; and require Governments to establish
the right legal and fiscal frameworks to facilitate and increase
investment in the research and development of new technology designs
for aircraft and aircraft engines, development of low carbon sustainable
alternative fuels, and longer term options such as improvements
in airspace management.
3.3.4 Under the global deal Governments should
ensure that any revenues from economic measures should be clearly
earmarked for environmental purposes. UNFCCC countries meeting
in Copenhagen should give ICAO a clear mandate and timetable for
developing and implementing the detail of such an approach
3.4 How important is it to the UK economy that
it becomes a leading developer and exporter of low carbon technologies?
What Government policy needs to be in place to do this?
3.4.1 The CBI's report Pulling Ahead: Innovating
for Low-Carbon Leadership, published in early September, calls
for the Government to maintain and improve the research and development
tax credit scheme, which encourages investment, to help Britain
lead the way in low-carbon innovation. It identifies various sectors
where the UK already leads in low-carbon technology, including
Rolls-Royce's Environmentally Friendly Engine initiative (see
Section 7 below).
3.4.2 The UK model for reducing CO2
emissions related to air traffic management is the first of its
kind in the world and NATS is looking to export its methodologies
in order to spread the benefit.
3.4.3 The UK already derives significant export
income from aerospace products and components. If the UK technology
base does not keep these products competitive against increased
pressure for carbon reduction, the major airframers will be forced
to procure such products elsewhere, or else UK industry will locate
elsewhere to maintain competitive advantage.
3.5 Are we seeing impacts of a downturn in demand
on investment in low carbon technologies? If so, how can this
be addressed given the need to meet long term targets? What obstacles
to investment are there?
3.5.1 Reducing fuel burn also reduces costs
significantly so the long-term incentive to find solutions remains
high and commitment to long term solutions remains embedded. However,
there is no doubt that the current recession is straining business
models and investment will increasingly be under scrutiny regarding
its ability to deliver.
3.5.2 Even with the recession, airlines are
still investing in new technology and SA member airlines have
between them placed orders for more than 80 A380 and Boeing 787
aircraft. These aircraft represent the next generation in their
category of aircraft. Recession will drive a reduction in capacity,
but many airlines are choosing to achieve this by retiring older
aircraft, rather than cancelling orders for new aircraft.
4. THE SA ROADMAP
4.1 In 2008 SA undertook an exercise to
develop a projection to 2050 for emissions of CO2 from
UK aviation, taking into account improvements in operational efficiency,
new technology, and a partial fuel substitution from sustainable
sources.
4.2 SA has projected that emissions of CO2
from UK aviation will rise until 2020 but will then level off
and fall to current levels or below by 2050. Importantly the projection
does not take into account the wider CO2 reductions
in other sectors that will be achieved through airlines' participation
in Emissions Trading. The projection relies critically on the
current and forward investments by both industry and government,
on the success of the various technology programmes and their
incorporation into aircraft fleets.
Note: This emissions forecast
is based on DfT forecast of demand published in November 2007
and actuals up to 2005. UK aviation CO2 emissions actually
fell in 2007 and 2008 and are expected to decline further in 2009.
5. BIOFUEL TECHNOLOGY
5.1 SA's Strategy contains a commitment to "review
periodically the potential and practicalities of alternative fuels
to aviation kerosene". Since that was published in 2005 considerable
progress has been made in evaluating and testing alternatives
to traditional crude-oil derived kerosene, to the extent that
this commitment is currently being reviewed and will be made more
challenging going forward.
5.2 Sustainably produced, lower carbon fuels
must offer aviation a "drop in" alternative to conventional
fossil-fuel based kerosene. They are not without their challenges—new
fuels must meet stringent international standards for commercial
jet fuel, production of feedstocks and refining capacity must
be scaled up, and globally-recognised sustainability standards
must be adhered to—but the potential environmental and energy
security benefits are considerable.
5.3 SA members including Virgin Atlantic, British
Airways, Airbus and Rolls-Royce have already participated in several
programmes to test the potential of lower carbon alternative fuels
including the first "proof of concept" flight in 2008
which was the culmination of months of detailed laboratory and
engine rig testing.
5.4 It is generally recognised that viable mass
alternatives to a liquid hydrocarbon fuel for commercial aviation
are still some years away. However, their technical certification
is proceeding rapidly, and it is expected that "drop in"
biofuel/kerosene blends will enter the normal jet fuel supply
chain within the next few years. The SA Roadmap offers a conservative
assessment that 20% of fuel for UK departing flights would come
from sustainable alternative sources by 2030, contributing to
a 10% cut in absolute CO2 emissions.
5.5 Through internationally recognised bodies
such as the Roundtable on Sustainable Biofuels (RSB), which includes
expert NGOs, academics, fuel suppliers and customers, common sustainability
standards can be developed at a global level. SA members are also
committed to supporting only the development of fuels which meet
a set of strict sustainability criteria.
5.6 International mechanisms will need to be
developed to account for their usage and to allow for flexibility
within the aviation biofuel supply chain. Revenues from EU ETS
and other environmental economic instruments could go into sustainable
biofuel feedstock cultivation and developing processing or refining
capacity, to provide a lower carbon alternative for aviation and
other transportation sectors. As there are limited, if any, technology
alternatives to fuel-powered jet engines in the 2050 timeframe,
priority should be given to providing the appropriate regulatory
and economic frameworks and incentives to allow rapid implementation
of sustainable biofuels in the aviation sector. We would be concerned,
however, about negative unintended consequences associated with
mandatory targets on UK or EU-departing airlines.
5.7 SA recognises that biofuels do not represent
a "silver bullet" for aviation's contribution to climate
change. We do believe they can offer an opportunity for significant
reduction in the carbon intensity of air travel for our passengers.
6. AIRFRAME DEVELOPMENTS
6.1 The Airbus A380 entered service in 2007
and is redefining the environmental performance of large civil
aircraft. The UK industry has an important role in the design
and manufacture of this aircraft, including production of the
wings and landing gear.
6.2 The A380 produces 10% less NOx per seat
and burns 12% less fuel per seat than other large aircraft currently
in operation, requiring less than 3 litres of fuel per seat per
100km in a standard cabin configuration. The A380 has an efficient
structure that incorporates more new material than any other jetliner
currently in service, with composite and other lightweight materials
accounting for more than 25% of its structure. The A380 also benefits
from the latest innovations in aerodynamics, reducing drag to
the minimum and improving fuel efficiency further.
6.3 The A350 XWB (Xtra Wide-Body) is Airbus'
response to market demand for a medium capacity long range wide-body
family and is planned to enter service within the next five years.
The A350 XWB confronts the challenges of fuel economy, rising
passenger expectations and increasing environmental concerns.
6.4 The A350 XWB has the most efficient structure
in terms of design concept, with an airframe made of more than
60% new materials, chosen for their superior weight and strength
properties. This design also allows weight savings via optimum
fibre lay-up and skin thickness tailored to the requirements of
the location. Excellent aerodynamics, together with advanced high
lift devices and advanced systems contribute to greater fuel economy.
7. ENGINE TECHNOLOGY
7.1 Rolls-Royce has made significant progress
towards meeting the challenging fuel-efficiency and NOx reduction
targets set by ACARE and endorsed by SA. This progress, coupled
with a commitment to current and planned research and technology
programmes (such as the Environmentally Friendly Engine programme,
EFE), provides visibility of the industry's commitment to meeting
the reduction levels specified in the ACARE targets. Options being
considered for future narrow bodied aircraft carry different noise
and fuel efficiency benefits
7.2 EFE is a five year, £95 million UK-funded
programme, started in 2006, aimed at delivering significant reductions
in CO2 and NOx emissions. Rolls-Royce is leading the
consortium of five UK aerospace companies and six universities.
7.3 EFE will produce and run a gas turbine core
that will be tested in a new, specially modified test-bed at Bristol.
The test programme, consisting of four different engine builds,
will allow the technology to be progressively developed, tested
and validated. This approach enables advanced technologies to
be incorporated into new commercial products in a short time frame
with reduced risk.
7.4 More recently, Rolls-Royce has been awarded
the 4-year, low-carbon research package SILOET (Strategic Investment
in LOw-carbon Engine Technologies), with £45 million of Government
funding, which will develop, low weight, low carbon and low emissions
technologies for future engines.
8. AIR TRAFFIC
MANAGEMENT
8.1 Air traffic control relies heavily on advanced
communication, surveillance and navigation technology to ensure
the safe and efficient movement of aircraft. It requires significant
ongoing investment in research and development of tools, systems
and procedures to improve service, and to improve environmental
efficiency by enabling aircraft to fly closer to their optimum
profile, minimise interaction with other traffic flows and regulate
speeds and level changes.
8.2 Innovations recently introduced or due on
stream in the short-term include Precision Area Navigation (P-RNAV);
arrivals and departure management tools; iFACTS (including 4D
trajectory management); Oceanic airspace management tools; airport
ground operations information tools (A-CDM);
8.3 Overall, NATS believes that 2% of its 10%
target to reduce ATM-related CO2 by 2020 will be delivered
by new tools and technologies. On conservative estimates, this
could equate to some 520,000 tonnes of ATM CO2.
8.4 Based on today's fleet composition and today's
fuel prices this would equate to an approximate £50 million
saving in fuel so there is a long-term cost incentive, as well
as environmental incentive, to continue investment and this is
supported by the airlines. The Arrivals Manager tool alone has
the potential to save as much as 300,000 tonnes of CO2
per annum—equivalent to 2,000 B747 transatlantic flights.
8.5 NATS has already achieved significant fuel
savings by enabling shorter routes through military airspace when
this is not in use. The close cooperation to achieve this "flexible
use of airspace" is now established and will increase in
the future. Wider airspace design and re-design is also critical
to maximum efficiency and therefore environmental improvement;
NATS has an ongoing programme to achieve route systems which accommodate
the optimum flight profile of different aircraft and to reduce
noise over the ground.
September 2009
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