Aviation

Purpose

This policy position statement outlines the global and local environmental issues with respect to aviation, and sets out the Institution's policy on aviation in the UK within this context.

CIWEM calls for:

• A Government review of the role of aviation as part of a low carbon travel and transport strategy and low carbon economy for the future.

• The Government to renegotiate Article 24 of the Chicago Convention which exempts international air travel from fuel duty. UK subsidies, taxes and duties need to be reassessed to make aviation pay for its environmental costs, deter short haul aviation and provide funds to reinvest into other transport infrastructure.

• The UK Government to secure an international agreement on measures to reduce aviation emissions on all greenhouse gases and not just carbon dioxide.

• An end to misleading advertising of air fares that encourage air travel, replaced with headline prices that reflect the true cost to the consumer. Adverts for flights to be required by law to mention prominently the resulting carbon emission.

• An end to new airport capacity in the UK with existing capacity focussed where it is needed most (e.g. for long haul flights and to connect isolated island communities).

• The Civil Aviation Authority and the Environment Agency to be given a legal duty and the necessary powers to require those in breach of air quality and noise limits to come back into compliance.

• Whole-network integrated travel options to reduce car travel to airports.

The Chartered Institution of Water and Environmental Management (CIWEM) is the leading professional body for the people who plan, protect and care for the environment and its resources, providing educational opportunities, independent information to the public and advice to government. Members in 98 countries include scientists, engineers, ecologists and students.

Context

Aviation is a major UK industry, carrying over 235 million passengers a year and over 2.3 million tonnes of freightⁱ. Travelling by air has brought many benefits to people's lives and to the UK economy. It has removed some of the limits of being an island nation by increasing our access to Europe and the rest of the world and brought wider benefits from tourism and business travel. Aviation accounts for a significant component of our economy with 25% of our trade by value carried by air freightⁱⁱ.

Whilst aviation is important for global commerce, CIWEM believes there needs to be a wider debate in the UK about the role of aviation in achieving a low carbon global economy and the equality of opportunity it provides. In recent years air travel has become cheaper, with the real environmental costs masked. One in five of the world's international flights depart or land in the UKⁱⁱⁱ. Yet air travel is mostly undertaken by the wealthiest 20% of the population with people on low incomes rarely flying^iv; therefore calls for aviation to pay for its environmental costs are not necessarily regressive. A review of aviation should consider the role of air travel in enabling prosperity both in the UK and in other parts of the globe, where people and businesses visit and trade, in tandem with equality of opportunity.

Aviation policy in the UK
Aviation policy and regulation in the UK generally rests with the Department of Transport and the Civil Aviation Authority (CAA), however the EU has overall competence in many areas relating to civil air transport^v.

The previous Government's policy on aviation was set out in the 2003 White Paper "The Future of Air Transport" ^vi. This concluded that air travel is essential to the UK's economy and stated that more should be made of existing capacity. It also supported the growth of regional airports to maintain regional economic development, increase choice, and reduce the pressure on the more over-crowded airports in the South East. The White Paper set out the Government's conclusions on the future development of airport capacity across the UK on a region-by-region and case-by-case basis.

Shortly after the election of the Coalition Government in May 2010, it was announced^vii that planning powers will be devolved to local government and community groups with the abolition of Regional Government Offices, Regional Development Agencies and the Infrastructure Planning Commission. These changes will all impact on aviation through changes to the funding and planning of airports. The Government has also specifically announced that the third runway at Heathrow will be cancelled, permission will be refused for additional runways at Gatwick and Stansted, and taxation will be reformed from a per-passenger duty (APD) to a per-plane duty (PPD). CIWEM believes that these are important commitments that the Government will need to adhere to. 

Discussion of issues

Climate change

The Climate Change Act (2008) binds the UK to an 80% cut in carbon dioxide (CO₂) emissions by 2050, with an interim milestone of at least 26% by 2020. In January 2009 the Labour Government set a target that in 2050 CO₂ emissions from UK aviation should not exceed 2005 levels^viii. The Committee on Climate Change (CCC) was asked was asked to advise on options for reducing emissions to meet this target and on its implications for aviation expansion in the 2020s. The CCC concluded that in order to reach climate change targets "deliberate policies to limit demand below its unconstrained level are [...] essential" ^ix.

UK domestic flights and international departures are one of the fastest growing sources of greenhouse gas (GHG) emissions and are currently responsible for around 6% of our total CO₂ emissions^x. Other particulates and compounds that cause radiative forcing¹ such as nitrous oxide and water vapour are also released by aircraft and have more impact when they are released at altitude. When these are included in estimates, the total radiative forcing from flights may be more than double the contribution that CO₂ makes^xi.

The CCC predicts that with planned capacity constraints and using a central case carbon price, (not including technological progress), emissions would rise to around 74 MtCO₂ in 2050. This is almost double the 2005 level of 37.5MtCO₂ and does not incorporate non-CO₂ emissions - which as scientific understanding improves will need to be accounted for^xii. In order to reach the commitments in the Climate Change Act^xiii the Government has proposed that the UK aviation target should be driven by the industry through fuel efficiency and with the addition of international flights to the EU ETS. CIWEM considers that policies to reduce air traffic movements will also be needed to reduce GHG emissions.

Emissions Trading
The EU Directive (2008/101/EC)^xiv to include aviation within the EU Emissions Trading System² (ETS) came into force on 2 February 2009. From 2012 all flights departing from and arriving at UK airports will be included in the EU ETS, and to comply with the Directive, aircraft operators have been required to monitor emissions from 1 January 2010^xv. 

CIWEM welcomes the change to the ETS to include all flights that depart from or arrive to UK airports, but considers that allowances need to reflect contraction and convergence principles for more equitable mitigation . Whilst trading allowances is a fair and cost effective mechanism for reducing emissions, in its current form the EU ETS does not include other greenhouse gases and previous phases of the scheme have been strict enough. The EU ETS may prove useful to reduce carbon emissions as an interim measure provided there are strong price signals and allowances are gradually decreased.

Emissions reductions from improved technology and fuel efficiency
The aviation industry^xvii claims that with improved technology such as new aircraft engines and airframes, more efficient air traffic management, the use of biofuels and other measures, CO₂ emissions can be reduced to 2000 levels by 2050 and still allow for passenger numbers to increase by a factor of three. This is set out in an industry-sponsored report^xviii which both WWF-UK and the Environment Agency have heavily criticised for relying on unproven technologies and insufficient incentives³. Manchester Metropolitan University have examined possible solutions for a 'greener' aviation industry. Based on some 40 technical studies they conclude that technology may provide the means to mitigate some of air transport's environmental externalities but that human behavioural change is also necessary^xix.

Carbon offsetting
Carbon offsetting is becoming increasingly popular and is now offered by tour operators and airlines. Whilst offsetting the carbon emitted from the flight by planting trees is a positive action, it should be viewed as a short term solution whilst behavioural change and technological advances begin to take effect. Offsetting has been criticised for perpetuating a 'business as usual' approach and allowing people to justify travelling by air.

Air Capacity and demand

Taxation and pricing
The prices paid by customers do not currently reflect the environmental costs of aviation due to subsidies, tax breaks and the lack of a real economic value attached to the environmental damage done by its emissions.

The Government needs to renegotiate Article 24 of the Chicago Convention which exempts international air travel from fuel duty. Adding VAT to fuel would help make aviation pay for its environmental costs and provide significant funds to reinvest in other transport infrastructure. One estimate suggests that aviation's tax advantages amount to £9 billion per year of lost revenue for the UK Treasury^xx. Air tickets and the purchase of aircraft equipment are also currently exempt from VAT.

Implementing an aviation fuel tax or charging for en-route flight emissions are other policy measures that could reduce air travel demand and increase revenue which the UK Government should press for international agreement on. 
 
The change to a per-place air duty (PPD) is welcomed by CIWEM as this will ensure that air freight is accounted for within the tax system and will provide more of an incentive to reduce the environmental impacts of planes through more efficient planes and fuller flights. We believe that PPD should be regularly reviewed and raised.

The House of Commons Transport Committee stated that "UK residents are taking the opportunity to travel by air increasingly often, with demand stoked by falling fares" ^xxi. Between 1997 and 2006 average airfares fell by around 50%^xxii. Many flights are sold with misleading headline prices which encourage people to take trips they might not normally have considered. CIWEM believes that air fares should be advertised with the final price that will be charged to the consumer alongside the carbon emission associated with the flight (which would be useful if personal carbon allowances became a reality). For example an advert for a London - New York return flight to include that 3.72 tonnes of carbon dioxide is emitted per passenger⁴.

There is significant competition between airlines and airports in the UK and 'budget' airlines have taken a considerable market share^xxiii. Although the sector is generally privately owned the Government has provided £1.5bn since 1997 in the form of repayable launch investments^xxiv. In August 2009 the Department of Business, Innovation and Skills provided £340 million of support to Airbus. These investments and subsidies could have been spent on other transport infrastructure.

Alternative transport
Improvements to rail services would reduce the need for domestic aviation and bring economic benefits from tourism and freight. CIWEM welcomes the commitment to establishing a high speed rail network in Britain and believes this will encourage more business travellers to use Eurotunnel links to Europe. The CCC have calculated that there is scope to reduce business travel (by up to 30%) through the increased use of teleconferencing, though this may need to be stimulated by price incentives.

Airport capacity
The previous Government supported the development of regional airports to contribute to economic development and employment. Regional airports handle over 40% of all UK air traffic and are important for the transfer of post and other time-sensitive goods such as newspapers^xxv. Air connectivity is vital for some businesses and communities in remote areas of the UK such as the Scottish Highlands and Islands^xxvi. Regional airports are largely served by low cost airlines and a number are financially dependent on one or two operators which can change their routes.
 
CIWEM believes that aviation capacity should be carefully planned and managed to ensure that it is focused in those areas where there is greatest need, alternatives are impractical and the local environment is duly protected.

Local environmental impacts

Many of the adverse impacts of aviation disproportionately affect local populations. Air transport creates noise, light and air pollution which impact on local biodiversity, heritage and communities surrounding airports and those under flight paths^xxvii.

As airports are often located near to major cities, their expansion frequently results in the erosion of local greenspace and greenbelts. If the proposed expansion of Bristol airport gains approval it will encroach on the greenbelt, an Area of Outstanding Natural Beauty and impact a SSSI containing species protected by the Local Biodiversity Action Plan. Protected areas need to stay as such.

Local roads become congested affecting the quality of life of the local population and adding to air pollution. Following the first three days of the closure of UK airspace in January 2010, air pollution near Gatwick and Heathrow dropped significantly. Levels of NO₂ (nitrogen dioxide) and NO_x (oxides of nitrogen) fell to almost zero showing the impact of road traffic resulting from travel to and from the airports^xxviii. The Eddington Transport Study^xxix recommended greater investment in surface access to airports such as rail links to reduce the local impacts of travel. CIWEM considers adequate public transport should service all airports and be considered and funded as a part of airport expansion schemes.

The amended Civil Aviation Act^xxx contains powers for airports to control noise and local air quality caused by aircraft. Penalties can be charged and the payments used for purposes to benefit people who live in the area of the airport. This is to encourage airlines to use quieter and less polluting aircraft and should be utilised more. The CAA (for noise) and the Environment Agency (for air quality) need to be given a legal duty and the necessary powers to require those in breach of limits to come back into compliance.

November 2010

Footnotes

1. Radiative forcing is a measure of the influence a factor has in altering the balance of incoming and outgoing energy in the Earth-atmosphere system and is an index of the importance of the factor as a potential climate change mechanism. Radiative forcing values are expressed in watts per square meter (W/m²).

2. The EU ETS started in 2005 as a cap and trade scheme. It works by capping total emissions to a fixed limit, with operators required to surrender allowances to cover their total emissions. If operators wish to increase their emissions from their share of the overall aviation limit, they must buy additional allowances from elsewhere within the ETS.

3. The SA report anticipates that 20% of total jet fuel uplift would come from biofuels by 2030. The CCC have stated that "it is not prudent to assume that biofuels in 2050 could account for more than 10% of global aviation fuel" due to concerns about land availability and sustainability. The CCC suggest that fleet fuel efficiency improvements of 0.8% annually in the period to 2050 are likely given technological trends and investment intentions.

4. Data from Atmosfair emissions calculator (http://www.atmosfair.de/en). Emissions calculations are for the aircraft divided by the number of passengers on board and also account for different pollutants which are converted into a CO₂  equivalent that have a comparable warming effect.

References

i. DFT. 2010. Aviation. Available from: http://www.dft.gov.uk/aviation/  

ii. HOUSE OF COMMONS TRANSPORT COMMITTEE.  2009. The Future of aviation, December 2009. Available from: http://www.publications.parliament.uk/pa/cm/cmtran.htm

iii.    CAIRNS, S., NEWSON, C. 2006. Predict and Decide: Aviation, Climate Change and UK Policy. Environmental Change Institute, University of Oxford.

iv. CAA Statistic. 

v. HOUSE OF COMMONS TRANSPORT COMMITTEE.  2009. The Future of aviation, December 2009.

vi. DFT. 2003. White Paper: The future of Air Transport. Available from:  http://www.dft.gov.uk

vii. CABINET OFFICE. 2010. Our programme for Government, May 2010.

viii. HC Deb 15th January 2009 c355 - 362. Available from:   http://www.publications.parliament.uk/pa/cm200809/cmhansrd/cm090115/debtext/90115-0005.htm#column_355

ix.   COMMITTEE ON CLIMATE CHANGE. 2009. Meeting the UK aviation target - Options for reducing emissions to 2050. Available from: http://www.theccc.org.uk/reports/aviation-report

x.   BRITISH AIR TRANSPORT ASSOCIATION. 2006. Fuel and fuel efficiency.

xi.    HC Deb 2nd May 2007 c1617W. Available from: http://www.publications.parliament.uk/pa/cm200607/cmhansrd/cm070502/text/70502w0005.htm
and
CAIRNS, S., NEWSON, C. 2006. Predict and Decide: Aviation, Climate Change and UK Policy. Environmental Change Institute, University of Oxford.

xii.   COMMITTEE ON CLIMATE CHANGE. 2009. Meeting the UK aviation target - Options for reducing emissions to 2050. Available from: http://www.theccc.org.uk/reports/aviation-report

xiii.   Climate Change Act. 2008 Chapter 27. Available from: http://www.opsi.gov.uk/acts/acts2008/ukpga_20080027_en_1

xiv.   Directive 2008/101/EC of the European Parliament and of the Council of 19 November 2008 amending Directive 2003/87/EC so as to include aviation activities in the scheme for greenhouse gas emission allowance trading within the Community.

xv.   EU. 2010. Environmental Policy Brief, July 2010. Available from: http://ec.europa.eu/environment/news/brief/2010_07/newsletter_07_2010.pdf

xvi.   MEYER, A. GCI Briefing. Contraction and Convergence.

xvii.   SUSTAINABLE  AVIATION. 2008. CO2 Roadmap. Available from: http://www.sustainableaviation.co.uk/images/stories/key%20documents/sa%20road%20map%20final%20dec%2008.pdf

xviii.   SUSTAINABLE  AVIATION. 2008. CO2 Roadmap. Available from: http://www.sustainableaviation.co.uk/images/stories/key%20documents/sa%20road%20map%20final%20dec%2008.pdf

xix.   HOUSE OF COMMONS TRANSPORT COMMITTEE.  2009. The Future of aviation, December 2009.

xx.   CAIRNS, S., NEWSON, C. 2006. Predict and Decide: Aviation, Climate Change and UK Policy. Environmental Change Institute, University of Oxford.

xxi.   HOUSE OF COMMONS TRANSPORT COMMITTEE. 2009. The Future of aviation, December 2009.

xxii.   COMMITTEE ON CLIMATE CHANGE. 2009. Meeting the UK aviation target - Options for reducing emissions to 2050. Available from: http://www.theccc.org.uk/reports/aviation-report

xxiii.   CIVIL AVIATION AUTHORITY. 2006. No-frills carriers: revolution or evolution, November 2006.

xxiv.   HOUSE OF COMMONS TRANSPORT COMMITTEE. 2009. The Future of aviation, December 2009.

xxv.   CIVIL AVIATION AUTHORITY. 2007. Air services at UK regional airports.

xxvi.   HOUSE OF COMMONS TRANSPORT COMMITTEE. 2009. The Future of aviation, December 2009.

xxvii. DFT. 2003. White Paper: The future of Air Transport. Available from:  http://www.dft.gov.uk

xxviii. BARRATT, B AND FULLER, G. 2010. Empty skies prove that airports cause pollution. Environmental Research Group at King's College, London. http://www.independent.co.uk/environment/climate-change/empty-skies-proved-that-airports-cause-pollution-say-researchers-1950672.html

xxix.  HM TREASURY & DEPARTMENT FOR TRANSPORT. 2006. The Eddington Transport Study: The case for action: Sir Rod Eddington's advice to Government, December 2006.

xxx.   Civil Aviation Act 2006 Chapter 4. Available from: http://www.opsi.gov.uk/acts/acts2006/ukpga_20060034_en_1