Memorandum submitted by the Aviation Environment
Federation
1. The Aviation Environment Federation (AEF)
is the principal UK non-profit making environmental association
concerned with the environmental effects of aviation and supported
by individuals and community groups affected by the UK's airfields
and airports. We promote a sustainable future for aviation which
fully recognises, and takes account of all its environmental and
amenity effects. These range from aircraft noise issues associated
with small airstrips or helipads to the contribution of airline
emissions to climate change.
SUMMARY
2. The following summarises our consultation
response:
— The budgets recommended by the Committee
on Climate Change, and those now published by the Government,
are inconsistent with the 2050 target as they fail to include
aviation emissions. These emissions, under Government forecasts,
are set to continue growing making their future inclusion in the
carbon budgets increasingly difficult.
— There currently seems to be a lack of
clarity within Government about the Committee's advice on how
aviation emissions should be accounted for. We are concerned that
the policies of the Department for Transport are currently out
of step with the commitment from the Department of Energy and
Climate Change to cut all the UK's emissions by 80% of 1990 levels
by 2050 and that DfT publications mis-state the advice of the
Committee.
— The integrity of the UK's carbon budgets
will be compromised if no restrictions are placed on the use of
credits from the EU ETS, as the ETS is insufficiently stringent
to be compatible with the goal of limiting global warming to no
more than 2°C.
Are the Committee on Climate Change's recommended
budgets to 2020 consistent with the UK's target for 2050?
3. We are concerned that the proposed carbon
budgets to 2020 fail to cover the UK's international aviation
emissions and that in this important respect the budgets would
be inconsistent with the UK's target for 2050.
4. There has been a great deal of confusion
about whether international aviation emissions are inside or outside
the UK's target to cut greenhouse gas emissions 80% on 1990 levels
by 2050. The advice of the Committee on Climate Change was as
follows:
The 80% target should apply to the sum of all
sectors of the UK economy, including international aviation and
shipping. To the extent that international aviation and shipping
emissions are not reduced by 80%, more effort would have to be
made in other sectors.
5. However, the Committee concluded:
International aviation and shipping should not
be included in budgets, but there need to be clear strategies
to achieve emissions reductions, and the Committee's annual reports
of progress against budgets should be accompanied by reports on
international aviation and shipping.... The Committee's annual
reports on progress in these sectors should keep under review
whether at any time it does become appropriate to include either
sector within the budget process.[2]
6. AEF welcomes the CCC's recognition that
emissions from international aviation must be included in the
UK's long-term target and the fact that the Government has accepted
this recommendation.[3]
7. We are somewhat concerned that some government
departments do not seem to have understood the (somewhat technical
but nevertheless clear) distinction between medium-term budgets
and longer-term targets. A recent Department for Transport publication,
for example, stated:
The Committee on Climate Change (CCC) recommended
on 1 December 2008 that the scope of the targets and budgets in
the Climate Change Act should not be extended to include international
aviation and shipping.[4]
8. If there is to be any chance of Government
departments demonstrating joined up thinking on this issue it
is important that all departments fully understand that commitments
that have been made, namely that the 80% target will apply to
the UK's share of international aviation (and shipping) emissions;
government policy made now needs to reflect this.
9. We believe, however, that leaving aviation
out of the carbon budgets is a mistake. We have long argued for
the importance of including aviation in the UK's carbon budgeting
strategy. In brief:
(i) We do not accept the argument that a lack
of international agreement about how to allocate aviation emissions
for the purposes of international climate policy is a good reason
for choosing not to allocate them for the purposes of UK policy.
The UK Climate Act does not require international assent. Annex
I parties to the Kyoto Protocol already report emissions from
international bunker fuels (aviation and shipping) annually as
a memo item to the UNFCCC; it would be straightforward to apply
the same methodology to the UK carbon budgeting system. While
it may be argued that such a decision may require review at a
future date if international consensus on allocation is forthcoming,
we believe it is likely to cause less turbulence and distortion
to the budgets than omitting these emissions altogether.
(ii) The CCC suggests that "the UK carbon
budget can be designed to take account of a reasonable estimate
of the UK's international aviation emissions and their likely
growth even if international aviation emissions are formally excluded
from the budget", and that the burden for making deeper cuts
to account for estimates of aviation and shipping growth will
fall on the sectors within the budgets. In fact the Climate Act
requires both the Secretary of State and the Committee on Climate
Change, when deciding on carbon budgets, to take into account
"the estimated amount of reportable emissions from international
aviation and international shipping for the budgetary period or
periods in question".[5]
Given that this estimate is to be made, we do not understand why
it should not be included in a straightforward manner into the
budgets.
(iii) Every credible projection for UK aviation
emissions concludes that unless there are radical changes in both
government policy and new technologies then these emissions will
continue to rise. Failing to include aviation in the carbon budgets
and thus allowing them to grow without effective controls is likely
to mean that every year we are a step further away from being
able to bring aviation emissions within the 80% target for 2050—something
to which the Government is now committed.
(iv) There is still no policy in place, even
for the future, to tackle aviation's non-CO2 impacts. The Climate
Act applies to `targeted greenhouse gases'. While we welcome the
decision to take account of climate damage beyond that of carbon
dioxide, we note that aviation's non-CO2 impacts are primarily
from NOx and from water vapour; neither of these are in the list
of targeted gases as they cause climate damage only at altitude.
While there is scope in the Act to amend the definition of targeted
greenhouse gases, the fact that the impact of aviation on the
climate is around twice that of carbon dioxide alone means that
the distortion from omitting aviation from the budgets is twice
as serious and makes it harder still to meet the objective shared
by the EU and UK of limiting global warming to no more than 2°C.
10. We therefore urge the Environmental
Audit Committee to press for Ministers to exercise their powers
as specified in the Climate Act to amend the Act to directly include
international aviation in the carbon budgets.
What are the issues around using emissions trading
(both credits from the EU Emissions Trading Scheme and carbon
offset credits) to meet the UK carbon budgets?
11. We are very concerned about the CCC's
recommendation that no restrictions be applied to the use of credits
from the EU ETS to meet the UK's carbon budgets.
12. There are two pieces of European climate
policy important for the UK's carbon budgets: the EU Emissions
Trading Scheme and the commitment to cut Europe's greenhouse gases
by 20% of 1990 levels by 2020. Europe has promised to increase
this target to 30% if a successful global climate deal is agreed,
though the working assumption in terms of sectoral caps is that
the reduction will be 20%. These two policy commitments have recently
been harmonised in the Climate and Energy Package. This specifies
that in order to meet the 2020 target, the burden of reductions
is to be split between traded and non-traded sectors; those covered
by the EU ETS will need to cut their emissions by 21% while non-traded
sectors need to make a cut of 10%.
13. The Committee's December report argues
that "As Europe's share of international aviation is included
within the EU ETS, with a total cap (aviation plus other sectors)
which is consistent with climate objectives, there is no necessity
to include international aviation emissions within the UK national
budget. Aviation will be subject to a carbon price which encourages
supply side abatement and demand constraint: and growth in Europe's
aviation emissions will have to be offset by more rapid reductions
in other sectors within Europe".
14. There are a number problems with this
short statement, however.
(i) The total cap, based on a 20% reduction in
greenhouse gases by 2020, is not consistent with the key climate
objective of limiting global warming to no more than 2°C.
The 20% target is based on political feasibility, not up-to-date
climate science. Even the CCC report, in its chapter on budget
setting, states in connection with the EU programme that "The
20-30% range straddles the sort of developed country reductions
which Chapter 1 suggested are likely to be required in order to
meet global climate stabilisation goals: 20% would be too low".[6]
Many NGOs believe that even a 30% cut would be insufficient and
that developed countries need to adopt an aggregate reduction
target of more then 40% to play a fair part in protecting the
global climate.[7]
(ii) If the cap agreed for Europe includes emissions
from aviation but the UK's budgets do not then non-aviation sectors
will be allocated higher caps than they should be. Phase III of
the EU ETS begins in 2013 and abandons the idea of national totals
in favour of a sectoral approach. Nevertheless, the CCC's UK target
for 2020 reflects, in part, what the Committee considers is the
UK's fair share of the EU commitment. If the next stage is for
the UK's capped total to be divided among all sectors other than
aviation and shipping then we are surely setting ourselves up
for failure in terms of meeting the EU's target. The CCC's goal
of defining policy that is consistent with EU policy has, in this
respect, failed.
(iii) Impact assessments for the inclusion of
aviation into the ETS from 2012 suggest there will be very little
impact on either "supply side abatement" or "demand
constraint". The impact assessment conducted for the European
Commission when the scheme was first proposed concluded that between
2005 and 2020, as a result of aviation's inclusion in the EU ETS
revenue tonne kilometres would grow not by 142% but by 135%. Emissions
would, the report suggests, grow by just 2.8% less than they would
have done under business as usual scenarios by 2020.[8]
A more recent assessment of the financial impacts of the scheme,
by Merrill Lynch, found that the impact on ticket prices will
range from between 1.5 and 5.2 Euros;[9]
we do not believe that such increases will lead to "demand
constraint". An independent report from the Tyndall Centre
concluded that the ETS as currently designed will have minimal
impact on aviation emissions.[10]
(iv) Growth in Europe's aviation emissions will
not necessarily be offset by reductions in other sectors in Europe
as the ETS allows for up to 50% of the reductions to come from
offset schemes elsewhere in the world. Aviation will have direct
access to CERs and ERUs for up to 15% of their emissions in 2012,
while from 2013 onwards this drops to 1.5%, to account for the
fact that aviation will benefit from much more lenient terms than
other sectors with respect to both the cap and the auction level.
But for the scheme as a whole, up to 50% of the required reductions
from 2013 can come from offset credits: an increase in access
compared with phase II.[11]
Non-aviation sectors will thus have less need for their EUAs and
will be able to sell them on to airlines, putting actual reductions
from the aviation sector even further out of reach.
How compatible are current Government policies
with achievement of the overall budget?
15. AEF does not believe that the Government's
policy for aviation expansion outlined in the 2003 Aviation White
Paper is compatible with achievement of the 2050 target to cut
UK emissions by 80%. While aviation is currently excluded from
the carbon budgets outlined this month with the 2009 budget, it
is essential, if the sector is to have any chance of being accommodated
in future budgets, that the right policy decisions are taken now.
16. We conclude by quoting Sir Nicholas
Stern, who wrote about this subject just prior to the announcement
of the 2009 budget:
The Budget can succeed in accelerating action
on climate change only if the rest of government policy is consistent.
For example, big transport decisions, such as the third runway
at Heathrow, should be taken only if they make sense in the context
of a coherent carbon and transport policy for the UK, and, preferably,
for Europe as a whole. I would be surprised if the construction
of a third runway at Heathrow passed that test...[12]
April 2009
2 December 2008, the first report of the Committee
on Climate Change, Building a low-carbon economy-The UK's contribution
to tackling climate change, Executive Summary. Back
3
16 October 2008, DECC press release http://nds.coi.gov.uk/environment/fullDetail.asp?ReleaseID=381477&NewsAreaID=2&NavigatedFromDepartment=True Back
4
March 2009, DfT, Reforming the Framework for the Economic Regulation
of UK airports, Annex 5 section 1.8. Back
5
Climate Change Act 2008, Clause 10 http://www.opsi.gov.uk/acts/acts2008/pdf/ukpga_20080027_en.pdf Back
6
December 2008, the first report of the Committee on Climate Change,
Building a low-carbon economy-The UK's contribution to tackling
climate change, page 110. Back
7
April 2009, Climate Action Network International, Position
on am Annex I aggregate target. Back
8
December 2006, Commission of the European Communities, Impact
assessment of the inclusion of aviation activities in the scheme
for greenhouse gas allowance trading within the Community. Back
9
September 2008, Merrill Lynch, Aviation in the EU ETS; an incentive
for efficiency http://www.london-accord.co.uk/accord_2008/reports/merrilllynch_aviation.pdf Back
10
November 2008, Bows A and Anderson K A bottom-up analysis of
including aviation within the EU's Emissions Trading Scheme. Back
11
December 2008, Europa Press Releases, MEMO/08/796: Questions
and Answers on the revised EU Emissions Trading Scheme http://europa.eu/rapid/pressReleasesAction.do?reference=MEMO/08/796&format=HTML&aged=0&language=EN&guiLanguage=en Back
12
April 2009, Stern N Enough green talk. Now make it happen.
TimesOnline http://www.timesonline.co.uk/tol/comment/columnists/guest_contributors/article6135687.ece Back
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