Transport CommitteeWritten evidence from the RSPB (AS 98)


i. The RSPB welcomes this inquiry and the opportunity to comment on aviation strategy in the UK. The Government’s aviation strategy is currently under consultation in the form of the Draft Policy Framework (DPF)1. This will set the overarching policy within which decisions about aviation and airports will be taken. We understand from the Department for Transport that any options ruled out by the Framework will not be considered by the Airports Commission which will report in 2015.

ii. We are concerned that Government appear to be signalling a presumption in favour of capacity expansion without giving due regard to the potential impacts this could have on climate change and the natural environment.

iii. To ensure that Government’s aviation policy framework is genuinely compatible with the principle of sustainable development and the Government’s own ambition to be the “greenest ever”, we recommend that:

1.International aviation emissions are not excluded from the UK’s Carbon Budgets

2.Better use of existing capacity and alternatives to flying are clearly prioritised over any capacity expansion, which should be seen as a last resort.

3.The ecological impacts of expansion should be a key consideration and any increase in capacity must not result in additional pressure on protected sites and species.

4.The Government should reaffirm the previous target to cap the sector’s overall emissions at, or close to, 2005 levels by 2050.

5.Appropriate environmental assessment is undertaken at an early stage if any site-specific proposals are put forward to ensure special places such as the Thames Estuary are protected. This should give irreversible impacts on wildlife, habitats and accessible green space equal weight alongside the noise impacts on local residents.

Background—RSPB position on aviation

iv. The Royal Society for the Protection of Birds (the RSPB) is the largest wildlife conservation organisation in Europe. We have 1.1 million members, and own or manage approximately 135,000 hectares of land for nature conservation on 200 reserves throughout the UK.

v. The RSPB considers that sustainability should be at the heart of decision-making. The RSPB’s policy and advocacy work covers a wide range of issues including planning and regional policy, climate change, energy, transport, and agriculture. As well as commenting on national planning policy issues, the RSPB’s professional conservation and planning specialists make representations on over 1,000 items of planning casework each year throughout the UK, including development plans and individual planning applications and proposals. We thus have considerable planning experience, including on major infrastructure projects such as ports and wind farms. The RSPB also makes over 100 planning applications a year on its own reserves and estate.

vi. Our approach to the aviation sector is underpinned by two principles: that all development should avoid unacceptable harm to wildlife, and that the UK must continue on the path to meeting its carbon budgets, as legislated for in the Climate Change Act (2008).

vii. The RSPB considers that human-induced climate change is the greatest long-term threat to humans and global biodiversity. Up to one third of land-based species on earth could be committed to extinction by 2050 if we do not act to address this problem. Rapid and deep emission cuts in all sectors are essential to avoiding dangerous climate change. An urgent challenge for the UK is therefore to tackle rising carbon emissions from transport and aviation in particular. The Committee on Climate Change (CCC) says that at least a 60% cut in domestic emissions is needed by 2030 to be on the path to secure a 90% cut (equivalent to at least 80% once emissions from international aviation and shipping are factored in) by 20502.

viii. It is therefore essential to ensure that the aviation sector makes a fair contribution towards meeting the UK’s overall climate change targets. This will require Government to commit to a sector-specific emissions target at least in line with the pre-existing 2009 one to limit the sector’s emissions to 2005 levels by 2050. It will also need robust mechanisms to ensure the sector is on track to meet the target, and a mechanism to review whether it is fit for purpose in light of developments in climate change policy and the scientific ability to accurately measure the impacts of aviation’s non-CO2 emissions. Since the UK airport system, in terms of planning permissions granted, is already close to the maximum number of passengers compatible with achieving the 2050 target, any growth in the sector should only be permitted when the industry has demonstrated that any growth is possible within emission limits that reflect the carbon budgets.

ix. Any new developments must be seen as a last resort and should avoid all unnecessary damage to places of high ecological value, particularly protected areas. In the recent past, the RSPB has objected to proposals for airport developments at both Cliffe and Lydd in Kent. The Cliffe proposal would have resulted in the single biggest destruction of a Site of Special Scientific Interest, a Special Protection Area or a Ramsar site ever in the UK. Following the RSPB’s 2002 campaign, Government decided not to support the Cliffe option. Since 2007, the RSPB has supplied evidence of the substantial ecological impact an airport at Lydd could have. A final decision is still awaited from the Secretary of State for Transport, following a public inquiry at which the RSPB presented evidence.

1. What should be the objectives of Government policy on aviation?

1.1 Aviation policy should be based on the following objectives:

Demand reduction, efficiency, and making best use of existing capacity should be prioritised over expanding capacity.

The aviation sector should make an appropriate contribution to meeting the UK’s carbon budgets, and any plans for capacity expansion should be demonstrably compatible with our carbon budgets.

Aviation should be one part of a coherent, overarching low carbon transport strategy for the UK.

e. Where does aviation fit in the overall transport strategy?

1.2 Aviation must be placed within the wider framework of the UK’s transport strategy, and should be part of a coherent, overarching low carbon transport strategy. Transport policy should ensure that demand for aviation is tempered by lower carbon alternatives, which, in turn, requires policy to ensure such alternatives are readily available and competitive in terms of cost, convenience, comfort, etc.. Examples of lower carbon alternatives to air travel that should be clearly prioritised over further investment in aviation include:

Schemes such as WWF’s 1-in-5 initiative, which promote the increased use of video-conferencing as a substitute for international business travel3.

Rail investments that encourage modal shift, including better intercontinental, high speed routes.

An accessible, high quality, low-carbon surface transport network.

1.3 RSPB recently co-published a report along with the Campaign to Protect Rural England and the Campaign for Better Transport, entitled The Carbon Impacts of High Speed 24. This report, undertaken by Greengauge 21, shows that High Speed 2 could provide higher CO2 savings but that it depends on stimulating modal shift from air travel to HS2.

2. How should we make the best use of existing aviation capacity?

b. Does the Government’s current strategy make the best use of existing capacity at airports outside the South East? How could this be improved?

2.1 The RSPB is concerned that Government’s current Draft Policy Framework starts from a place of assuming that there is an impending “capacity challenge”. This assumption is questionable given conclusions from analysis done by WWF and the Airport Environment Foundation. Reducing demand and making best use of existing capacity should be the priorities for the Aviation Policy Framework. The WWF/AEF findings demonstrate that if the industry stays within a growth limit target which the CCC have advised on (60% growth in demand by 2050, and 2050 emissions no higher than those in 2005) there is currently enough spare capacity to meet demand out to 2030 and even most of demand by 20505. The shortfall is not of a scale that would justify the kinds of expansion being put forward by the aviation industry or the assumption of an impending capacity challenge.

2.2 Regional airports in particular, and airports in the London area other than Heathrow, have substantial unused capacity which could be exploited (Gatwick’s situation is much less urgent than Heathrow’s since it currently operates with 15% spare runway capacity)6. This could avoid the need for costly and environmentally damaging investment in new capacity in the UK. In addition, more strategic distribution of the kinds of flights offered at different airports would ensure that the UK made best use of existing capacity.

2.3 AEF and WWF conclude that a new airport in the South East is not justified, given the urgent limits that must be placed on aviation demand to help the UK achieve its climate change objectives. They also believe that very little new airport expansion is justified anywhere in the UK on the basis of these figures: spare runway and terminal capacity that already exists can be used to accommodate increases in demand and flights. The RSPB urges Government to carefully consider these conclusions and we recommend that Government invest far more into measures which could help to make better use of existing capacity. Possible mechanisms to achieve this would be to adjust relative airport charges in order to make hub slots more expensive and encourage carriers to shift point-to-point leisure flights to regional airports.

3. What constraints are there on increasing UK aviation capacity?

3.1 Constraints should include avoiding unnecessary impacts on the natural environment and on the UK’s climate change commitments through the Climate Change Act. Demand should in turn be limited in order to ensure that these environmental limits are not breached.

a. Are the Government’s proposals to manage the impact of aviation on the local environment sufficient, particularly in terms of reducing the impact of noise on local residents?

3.2 The DPF refers to the likely requirement of a National Policy Statement (NPS) on aviation—the RSPB welcomes this commitment, particularly in the case that Government proposes some expansion.

3.3 The NPS should be a first step before any decisions on specific expansion proposals are taken. The NPS should include strategic location-specific options for expansion and compare them on sustainability grounds. For example, the Nuclear NPS set an important precedent in that it was location specific and its Appraisal of Sustainability was conducted by independent consultants7. We recommend that the same approach be taken for any aviation NPS—it should include specific locations and a thorough examination of the impacts of alternative sites.

3.4 The test of environmental sustainability for new infrastructure laid out under an NPS of this kind should be an appropriate Strategic Environmental Assessment and a Habitat Regulations Assessment if any European site is threatened by a proposal, all as part of an Appraisal of Sustainability (AoS).

3.5 Previous Appraisals of Sustainability (AoS) have been of poor quality8. As the Strategic Environmental Assessment Directive sets out, any AoS must include a sufficient number of reasonable (as opposed to feasible) alternative options. Otherwise, consideration of sustainability could risk being left until the public consultation phase when such alternatives would effectively have been ruled out. This means that the RSPB is calling for:

An aviation NPS which is specific about locations where expansion might take place

An independent Appraisal of Sustainability applied to an aviation NPS

Habitats Regulation Assessment and Strategic Environmental Assessment as part of an Appraisal of Sustainability

b. Will the Government’s proposals help reduce carbon emissions and manage the impact of aviation on climate change? How can aviation be made more sustainable?

3.6 Government’s proposals on aviation’s contribution to climate change Draft Policy Framework, are not extensive. We do not believe that the proposals, as they stand, will lead to a significant decrease in aviation emissions and will in fact permit an increase.

3.7 Emissions from aviation are growing faster than any other transport sector. By 2050, aviation could be responsible for 25% or more of the UK’s total greenhouse gas emissions. The right policy levers still do not exist to reduce emissions and ensure that aviation’s contribution to mitigation is in line with other sectors of the economy.

3.8 The Department for Transport’s own most recent forecasts predict an increase in emissions from aviation9. Emissions in 2005 stood at 37.5 MtCO2. The Committee on Climate Change advised the previous Government on how to keep 2050 emissions no higher than 2005 levels10. However, DfT’s forecasts from 2011 predict emissions in 2050 to be anywhere between 39.6–58.4 MtCO2. We do not believe that the mitigating measures laid out in the Draft Policy Framework by Government will sufficiently abate this increase. We understand that DfT are currently producing new forecasts, but these are not immediately available.

3.9 The Draft Policy Framework’s approach to climate change is to prioritise international action, followed by European and finally domestic action on emissions. While we recognise the importance of any eventual global agreement and of course of improving the EU ETS, this hierarchy of priorities should be reversed.

3.10 Relying on international and European mechanisms to abate emissions from aviation does not give due consideration to our domestic climate change commitments. Furthermore, it results in delaying action to reduce emissions by linking action to the success of processes that Government are able to influence but not determine. Problems with sustaining a sufficiently high carbon price within the EU ETS and the low likelihood of any international agreement in the near future mean we recommend reversing the hierarchy and putting domestic action ahead of EU measures and, finally, international action. Government should prioritise domestic actions, including:

Limits to demand growth and capacity expansion, in line with the Committee on Climate Change’s recommendations

Including international aviation emissions in the Climate Change Act 2008 and the UK’s carbon budgets

3.11 The International Civil Aviation Organisation (ICAO) is the forum through which the UK works with other countries in an attempt to secure a global deal on aviation emissions. Regrettably, it is unlikely that any global agreement under ICAO will be achieved in the foreseeable future given the lack of progress in this forum to date.

3.12 At the EU level, the RSPB welcomes the inclusion of international aviation emissions in the European Emissions Trading Scheme, and applauds the EU’s strong response to resistance from other countries to this arrangement. The EU ETS promises to be an important tool to reduce emissions in a cost-effective way in the long-term, however it continues to be marred by implementation problems, such as the over-allocation of allowances, which have meant that it has so far largely failed to reduce emissions significantly11.

3.13 The RSPB therefore does not believe that the inclusion of aviation emissions in the EU ETS alone is sufficient, both in terms of mitigation effort for the sector and in terms of accounting for emissions from aviation.

3.14 The Committee on Climate Change have advised Government that limiting aviation growth is “likely to require policy measures to restrain demand which go beyond our central projected carbon price”, either through economic measures or the planning system, to a maximum of a 60% increase in passengers (or a 55% increase in air transport movements (ATMs)). These are far more ambitious than what was set out in the previous White Paper12. The CCC recommends that beyond the carbon price, additional instruments could be used to limit demand growth, including an additional tax on CO2 and restrictions on the allocation of take-off and landing slots. Other regulatory and fiscal measures that could be introduced to reflect the true cost of carbon and other greenhouse gases include:

Reversing the tax exemption for aviation fuel.

Retaining and strengthening air passenger duty (APD) or re-considering a switch to per-plane tax

Supporting taxes on non-CO2 pollutants such as nitrogen oxides

3.15 The 2050 Aviation Target (limiting the sector’s emissions to 2005 levels of 37.5 MtCO2 by 2050) adopted by the previous Government is in line with advice from the CCC on aviation’s contribution to the UK’s overall climate targets, and provides a mechanism to limit aviation emissions. At the very least, a renewed commitment to this target would be welcome. The RSPB’s view is that in order to avoid placing greater burdens on other sectors of the economy to decarbonise, interim targets should be put in place to ensure that emissions do not peak at higher levels ahead of 2050 to ensure the industry is on track to meet the target. It is essential to keep in mind that the non-CO2 global warming effects (which approximately double the impact of aviation’s emissions) are not included in the 2050 Target. The Target should therefore be reviewed periodically to take account of developments in the understanding of aviation’s non-CO2 climate impacts, and adjusted once these are included in carbon budgets.

3.16 Industry are concerned that unilateral domestic action will lead to emissions leakage—aviation moving overseas and taking its emissions with it—a concern that is routinely over-stated by the industry. This is borne out by the strong growth of UK aviation despite the fact that APD is several times higher than equivalent taxes in neighbour countries.

3.17 These are the constraints on the industry required as part of an economy wide effort to stop dangerous climate change. The aviation industry must demonstrate how it can meet these constraints if it wishes to continue to grow.

3.18 The RSPB believes that Government must not exclude international aviation (and shipping) emissions in the Climate Change Act and the UK’s carbon budgets. Anything else would amount to undermining the credibility of the Act and exempting one particular industry from the same standards applied to others in our economy. This will ensure that the industry is legally obliged to reduce its CO2 emissions. The Committee on Climate Change has provided detailed advice on how to include these emissions. It explains that inclusion is merely a technicality since the carbon budgets have to this date accounted for, although not formally included, these emissions. However, to omit them would be akin to a change in the status quo and a watering down of the UK’s commitments under the Climate Change Act.

3.19 We understand from the Department for Transport that the Airports Commission will operate and take decisions within the Policy Framework. If this framework remains as it is and Government were to decide not to include international aviation emissions in the carbon budgets, there would be next to no meaningful climate change limits which would influence the Commission’s decision.

3.20 The Draft Policy Framework sets out the role that Government hope biofuels will play in decarbonising the aviation sector. The RSPB would urge extreme caution towards the claims being made about biofuels’ ability to deliver significant greenhouse gas savings, the sustainability of their production, and imminent introduction into widespread service.

3.21 The Committee on Climate Change’s Bioenergy Review determines that a combination of land-use change and emissions associated with the processing of biofuel crops can significantly undermine emissions savings. The CCC outlines a Constrained Land Use scenario, in which the bioenergy supply is constrained in line with stringent environmental regulation to protect natural habitats. In this scenario there is only a very limited amount of available sustainable bioenergy—amounting to 1.4% of total global primary energy supply13.

3.22 Nonetheless, given the range of decarbonisation options available to the surface transport sector, the UK should transition to using the majority of available sustainable biofuels in aviation, where the options for decarbonisation are far more limited. As long as appropriate safeguards are in place, such as stringent and sector-specific sustainability standards, this transition could provide an “exit route” from the UK’s Renewable Transport Fuels Obligation, which commits us to levels of biofuel use that could easily exceed available sustainable supply. This would allow existing biofuel plant to continue operating, while putting aviation’s biofuel needs ahead of those of surface transport.

c. What is the relationship between the Government’s strategy and EU aviation policies?

3.23 The Government’s strategy depends heavily on the role of the EU Emissions Trading Scheme to reduce emissions from aviation. However, as explained in paragraphs 3.13–3.15 we do not believe that the mechanism in its current form can be relied upon to produce meaningful emissions reductions in the sector. Adjustments to the scheme in its Phase III period, beginning in 2013, could make it viable but there is no guarantee that they will successfully resolve its numerous problems14. Our key concerns are:

The cap on aviation under the EU ETS is not currently strict enough for it to deliver significant emission reduction levels.

Legal challenges from non-EU countries continue to beset the decision to include aviation.

A track record of over-allocation of permits has resulted in a failure of the scheme to drive emissions reductions15. Over-allocation can lead to price crashes; a recent price crash (the third in the scheme’s history) in April 2012 saw the carbon price reach a record low of €5.99.

4. Do we need a step-change in UK aviation capacity? Why?

4.1 As described in paragraphs 2.1–2.3 above, we do not support the idea that there is an urgent need for new airport capacity in the UK in the immediate or even medium-term future. The real step change which is needed in UK aviation capacity is to use existing capacity better, and encouraging the use of lower carbon alternatives to aviation.

a. What should this step-change be? Should there be a new hub airport? Where?

4.2 Claims that the UK’s connectivity is falling behind also seem to be prey to exaggeration. For example, Heathrow has 990 departure flights each week to the world’s key business centres. That is more than its two closest rivals, Charles de Gaulle (484) and Frankfurt (450), combined.

4.3 As detailed above, there is good evidence of plenty of spare capacity already present in the aviation sector, both in terms of runway capacity and terminal capacity. Such evidence seriously undermines calls for an expensive brand new hub. More sustainable, politically easier and more financially sound options are available, primarily better use of this existing capacity.

b. What are the costs and benefits of these different ways to increase UK aviation capacity?

4.4 If expansion is undertaken without respect for our carbon budgets, then it will be at the cost of the UK’s international leadership position on climate change, and our ability to meet our carbon targets, and thus our goal, agreed at the international level and enshrined in the Climate Change Act (2008) of keeping the world within safe limits of climate change.

4.5 If aviation emissions are permitted to rise and our overall emission target is to be met, other sectors of the economy would have to make deeper emission cuts, placing a greater financial burden could be based on other industries.

4.6 The benefits of limited expansion, which reduces and limits demand for aviation would be a shift of demand to other forms of transport. It would also ensure maximum benefits were reaped from investments in projects such as HS2, which, as evidence shows, provide maximum CO2 reductions per pound invested if demand shifts from high-carbon forms of transport such as flying.

24 October 2012

1 Department for Transport, Draft Aviation Policy Framework, 2012

2 Committee on Climate Change, Meeting the UK aviation target – options for reducing emissions to 2050, December 2009

3 WWF, One in Five Challenge: Annual Report 2009/10,

4 Greengauge 21, The Carbon impacts of HS2, 2012

5 WWF/AEF, Available UK airport capacity under a 2050 CO2 target for the aviation sector, 2012

6 Ibid.

7 Collingwood Environmental Planning (2010), Appraisals of Sustainability and the New National Policy Statements: Opportunities Missed and Challenges to Come? Final Report to RSPB and WWF, January 2010

8 Ibid.

9 Department for Transport, UK Aviation Forecasts, August 2011

10 Committee on Climate Change, Meeting the UK aviation target – options for reducing emissions to 2050, December 2009

11 Sandbag, Rescuing the EU ETS from redundancy, 2009

12 Committee on Climate Change, Meeting the UK aviation target – options for reducing emissions to 2050, December 2009

13 Committee on Climate Change, Bioenergy Review, December 2011

14 Open Europe, Europe’s Dirty Secret: Why the EU Emissions Trading Scheme isn’t working, August 2007

15 Sandbag, Rescuing the EU ETS from redundancy, 2009

Prepared 31st May 2013