Email the questions and responses to NZaviationconsultation@dft.gov.uk stating your name, address and postcode.
1 Do you agree or disagree that UK domestic aviation should be net zero by 2040? How do you propose this could be implemented?
Agree. However, domestic flights account for just 4% of UK aviation emissions so greater ambition is needed for international aviation. One key implementation measure would be to stop further expansion of UK airport capacity, at least until significant and proven carbon reductions have been achieved through efficiency measures such as the long-delayed Airspace Modernisation. At the same time, prudent measures such as taxing aviation fuel, adding VAT to ticket sales and imposing a frequent flyers levy should be implemented to manage demand downwards in the crucial next 10 years. Another measure would be to incentivise the use of more sustainable alternative forms of transport such as rail for domestic journeys.
2 Do you agree or disagree with the range of illustrative scenarios that we have set out as possible trajectories to net zero in 2050? Are there any alternative evidence-based scenarios we should be considering?
Disagree. The scenarios in Jet Zero are not adequately evidenced either in the consultation material or the supporting document. Jet Zero itself says: “There is significant uncertainty surrounding the abatement potential, uptake and costs of the measures described in this document and therefore these scenarios should be seen as illustrative pathways rather than forecasts.” In reality, there is no realistic scenario or forecast in which technological and fuel developments can, on their own, make flying net zero by 2050. As the Climate Change Committee has advised, demand management measures, including an immediate halt on all airport expansions, are essential to control aviation emissions in the next 10 years. The IPCC has warned that global emissions must be cut by 45% by 2030: Jet Zero proposes to allow UK aviation emissions to increase into the 2030s. Until evidence-based technological alternatives are available, demand management and prioritisation, coupled with use of tax so that the polluter pays towards reducing aviation emissions by supporting investment into genuinely sustainable alternatives, is the only responsible approach.
3 Do you agree or disagree that we should set a CO2 emissions reduction trajectory to 2050?
Agree. But the measures proposed to achieve that reduction must be realistic, evidence based and reliable. As advised by the IPCC, we must make actual emissions reductions by 2030 – Jet Zero proposes an increase. The high level of uncertainty attached to all of Jet Zero’s technical solutions (which is accepted in Jet Zero itself) means that demand management measures are urgently required in addition to the proposals set out in the draft strategy. Offsetting cannot reduce emissions sufficiently in the short term, and alternative fuels are not yet established at scale and nor is it clear that sufficient biomass could and should be available to fuel aviation. The new technologies such as Zero Emissions Flight and electric or hydrogen powered are simply not going to be available in the timeframe required.
a. Should the trajectory be set on an in‑sector CO2 emissions basis (without offsets and removals) or a net CO2 emissions basis (including offsets and removals)?
In‑sector CO2 emissions basis. Offsetting should not count towards reaching net zero, as advised by the CCC in the 6th Carbon Budget. Offsets are at best an addition, not an alternative, to controlling emissions in the next 10 years. Carbon removal at scale has not yet been deployed and proven to the extent necessary: again using tax to reduce aviation demand and creating money for investment in developing such technology would be a prudent strategy.
b. Do you agree or disagree with the possible trajectories we set out, which have in-sector CO2 emissions of 39 Mt in 2030, and 31 Mt in 2040 and 21 Mt in 2050, or net CO2 emissions of 23-32 Mt in 2030, 12‑19 Mt in 2040 and 0 Mt in 2050?
Disagree. Climate scientists on the IPCC and the CCC warn that we must make radical cuts to emissions in the next 10 years in order to have any realistic prospect of reaching net zero by 2050. There is no soundly-based justification for allowing aviation emissions to increase up to 2030: the quoted figures for jobs sustained by the aviation sector are notoriously over-stated, and the ONS confirmed a net £33bn balance of trade deficit in tourism in 2019. Such a policy would contradict the government’s new target of cutting UK emissions by 78% by 2035.
4 Do you agree or disagree that we should review progress every five years and adapt our strategy in response to progress?
Disagree. The urgent nature of the climate emergency and the need to provably reduce emissions in the next 10 years means that there should be annual reviews of the aviation industry’s emissions and the extent to which they are (or are not) reducing. Government strategy should rapidly adapt if emissions are not reducing at all or not reducing fast enough. It is deeply irresponsible to put off achieving any progress until potentially too late. The priority should be to establish a more realistic and lower-risk carbon reduction trajectory by 2022 which front-loads rather than back-loads reduction.
5 Do you agree or disagree with the overall approach to improve the efficiency of our existing aviation system?
Disagree. The assumption of 2% pa efficiency gains is a dangerous over-estimate and is not based on credible evidence. Evidence from the CCC and ICAO shows that 1.4% pa is the highest realistic rate. There is no evidence yet of the efficiency gains from Airspace Modernisation, and the Future Airspace Strategy Implementation has been further delayed by the COVID-19 pandemic. Ground operations emissions are small compared to the in-flight emissions, and the gains from modal shifts to more sustainable surface transport need yet to be demonstrated.
6 What more or differently could be done to ensure we maximise efficiency within the current aviation system?
Airlines have become increasingly cost-conscious in a highly competitive environment for 10-20 years and it is therefore implausible that efficiency measures which will significantly reduce fuel burn (hence emissions) other than airspace modernisation, remain to be discovered. New “neo” engines are being introduced which claim 15% fuel reduction, but development and deployment of more efficient aircraft engine or airframe technology in the next 10-20 years is implausible. That is why the government strategy should include immediate demand management measures designed to manage emissions towards more sustainable levels, at least until the other carbon reduction measures it proposes become more than aspirational.
7 Do you agree or disagree with the overall approach for the development and uptake of SAF in the UK?
Disagree. First, there are huge uncertainties about the potential for scaling up SAF production and associated infrastructure development, such that SAF cannot reasonably be relied upon to the extent proposed in Jet Zero. For example, the area of land required to grow enough crops to produce biofuels to power an unconstrained increase in flying is so large that humanity would likely have to choose between eating or flying. Secondly, this is a priority need solely for the aviation industry so the aviation industry should meet the full cost of developing and deploying SAF. It should not be borne by the taxpayer as there are more effective uses of public funds to mitigate the climate crisis and adapt to its unavoidable impacts. A small minority of the UK population take the majority of flights while a significant proportion of the population does not fly at all in any given year. The cost of developing SAF should be borne by those who will use SAF.
8 What further measures are needed to support the development of a globally competitive UK SAF industry and increase SAF usage?
The question implies an assumption that SAF should be scaled up for the benefit of aviation, whereas we disagree that this is necessarily the case and a balanced strategic consultation ought to examine this question. A more balanced view should first be taken on the best way to deploy the biomass and the energy which would be required to generate synthetic fuels. There is no evidence apart from the assertions of the DfT that aviation should take priority where resources are scarce. In fact, given that aviation emissions are some three times more damaging to the climate than emissions from other sectors (contrails, high altitude NOx), it is irresponsible to imply that aviation must be given priority. Given that we do not have the luxury of time, demand management measures (ceasing further expansion of UK airport capacity, using tax to influence down demand) should be introduced immediately, and maintained until other strategic aspirations are proven.
9 Do you agree or disagree with the overall approach for the development of zero emission flight in the UK?
Disagree because it implies that this will be a solution for net zero by 2050. Electric flight will not be viable for anything other than short haul, small aircraft, even by 2050. Hydrogen-based commercial aircraft face huge obstacles and uncertainties regarding the development, scaling up and commercial deployment of both planes and infrastructure, so cannot reasonably be relied upon to the extent proposed in Jet Zero. these technologies should be developed, but should not be relied on as short to medium term solutions.
10 What further measures are needed to support the transition towards zero emission aviation?
Immediate introduction of effective demand management measures which generate revenue for investment in the technology and infrastructure which aviation will require in order to be genuinely sustainable. This means no increase to the capacity of UK airports, and using tax to manage demand downwards over the next 10 years. Introducing taxes on the fossil fuels used to fly aircraft, at a rate that realistically reflects their climate damaging costs, is an urgent priority. These measures are essential, if only to provide ‘breathing space’ for the development, testing, monitoring and deployment of the aspirational technical solutions proposed in Jet Zero.
11 Do you agree or disagree with the overall approach for using carbon markets and greenhouse gas removal methods to drive down CO2 emissions?
Disagree. The UK ETS and CORSIA are inadequate methods to meaningfully offset aviation emissions. There is low little risk of ‘carbon leakage’ from domestic UK flights or flights from the UK to EU destinations, so the ETS as currently constructed is unlikely to reduce emissions. The CCC specifically rejected counting CORSIA offsets towards the UK’s 2050 net zero trajectory – offsetting is at best an addition, not an alternative, to controlling aviation emissions.
Greenhouse gas removal (GGR) technologies are nascent and the timescale for their scaling up is very uncertain, so they cannot reasonably be relied upon to the extent proposed in Jet Zero. The immediate introduction of measures to manage demand downwards in the next 10 years is vital to limit the amount of emissions that will need to be removed in future.
12 What could be done further or differently to ensure carbon markets and greenhouse gas removal methods are used most effectively?
Make the price for each tonne of CO2e offset credit equivalent to the actual cost of GGR technologies that have been proven to remove emissions from the atmosphere. Properly apply the ‘polluter pays’ principle by the immediate cessation of giving free credits to the aviation industry via the UK ETS.
13 Do you agree or disagree with the overall focus on influencing consumers?
Whilst providing information is a start, it is unlikely to create a significant shift in behaviour particularly given the mixed messages from government and the misleading information about the true costs and benefits of flying. A genuine consultation would need to involve an independent review of the economic and environmental evidence, and to take into full account the key messages from the CCC and the IPCC. Yet the proposals in the Jet Zero consultation are still based on the aspiration that aviation should continue to grow, proving that this is not a genuine consultation at all. Government should introduce demand management measures as soon as possible to buy time for a more reliably evidenced trajectory to be developed.
14 What more can the Government do to support consumers to make informed, sustainable aviation travel choices?
Introduce significant taxes on aviation fossil fuel (the polluter should pay) and add VAT to ticket sales (few flights can be regarded as ‘essential’). Switch public subsidies to low carbon, ground transport in order to make sustainable choices more comparatively affordable.
15 What could be done further or differently to ensure we tackle non-CO2 impacts from aviation?
Implement the CCC’s priority recommendation in its Progress Report to Parliament in June 2021: “There should be no net expansion of UK airport capacity unless the sector is on track to sufficiently outperform its net emissions trajectory and can accommodate the additional demand. A demand management framework will need to be developed (by 2022) and be in place by the mid-2020s to annually assess and, if required, control sector GHG emissions and non-CO2.”