17th December, 2019
Have they included aircraft emissions? It’s the question we ask ourselves every time we see a new climate commitment, whether that’s airports saying they’re going carbon neutral, businesses and states committing to ‘net zero’, or claims about successful carbon cutting measures having being delivered in the UK.
The Kyoto Protocol, adopted in 1997, left international aviation and shipping (IAS) out of the commitments made by industrialised countries to cut emissions. Instead, it requested states to work with the UN agencies responsible for the aviation and maritime sectors to find solutions to their growing CO2 impacts. In practice, this created a policy black hole that has never been properly addressed since.
The UN aviation agency, ICAO, whose meetings are attended largely by the world’s transport officials, spent many years considering, but mostly failing to agree on, any meaningful measures to limit CO2 from flying. The creation by ICAO of an offsetting scheme to meet an unambitious goal of ‘carbon neutral growth’, the Carbon Offsetting and Reduction Scheme for International Aviation, was prompted in part by opposition to the EU’s inclusion of aviation in Europe’s emissions trading system (ETS).
But even if successfully implemented (some large states have yet to commit to participate) the scheme, which is due to begin next year, will only address growth in emissions above their level in 2020 – emissions below that level will be unaccounted for – and its reliance on offsetting means it won’t address aircraft emissions themselves. And as the years have passed and policy debates have rumbled on, air fares have been getting cheaper, airports have expanded, and emissions from air travel have been growing.
The UK’s climate law, the 2008 Climate Change Act, left aviation and shipping emissions in a kind of limbo. The Act was supposed to represent the UK’s fair share of emissions cuts in line with limiting to 50% the risk of exceeding 2 degrees of global warming, so implicitly applied to all sectors. But international aviation and shipping were left out of the 5-yearly carbon budgets that the Act requires, on the basis that it remained unclear how to account for these emissions. The Act required them to be included by 2012 unless the Government could explain to Parliament why this wasn’t possible. The Government went for the latter option and left them out, citing ongoing uncertainty in relation to the treatment of aviation under the EU ETS.
Carbon budgets for other sectors have nevertheless always been set with a view to including aviation and shipping at some time in the future, allowing ‘headroom’ for these emissions. The budgets so far legislated (under the former 80% target) allow for aviation emissions in 2050 to take up around a quarter of the UK’s total allowable CO2. Getting the Government to act as though this represents any kind of meaningful limit, however, has always been a challenge. While the maximum allowable ‘headroom’ was, for example, noted in the work of the Airports Commission when it recommended a new runway in the South East, the policy implications of keeping aviation emissions down to that level while building a third Heathrow runway never made it off the pages of deeply buried scenario analysis (which assumed massive hikes in ticket prices to keep passenger numbers down at other airports).
The Government’s Aviation Strategy Green Paper claimed to support the (now historic) recommendation of its statutory climate advisory body the Committee on Climate Change (CCC) to limit aviation emissions to 37.5 Mt. But it also set out strong support for growth at airports around the country to help cater for demand forecasts that would generate over 40 Mt of emissions. Many airports themselves anticipate even more growth, and very likely therefore higher emissions, than assumed by the forecasts.
The CCC recently stuck its neck out on the issue. Now that the UK has committed to an even tougher emissions target – net zero greenhouse gases by 2050 – it’s time to get the aviation and shipping issue tied down and to pass additional legislation that formally includes these sectors in the UK’s legal obligations, CCC has said. In a letter to the Transport Minister Grant Shapps the committee argues that it is ‘strategically important’ to address aviation and shipping emissions through formal inclusion in the UK’s domestic legislation, and that this would complement, not compete with, international policies such as CORSIA. In terms of UK aviation policy and airport development, without putting too fine a point on it, the Committee suggests that “formal inclusion of IAS emissions would help to guide long-term policy approaches and infrastructure investment decisions.”
As the Committee itself carefully noted in the letter, when the Government passed net zero legislation earlier this year it made clear that it intended the 2050 target to apply to all sectors including aviation and shipping. When pressed on what this means, however, the transport department has been non-committal. Worse, the Government’s response to the CCC’s Progress Report (which covered the whole economy, but included the recommendation on putting aviation and shipping in carbon budgets in advance of the Grant Shapps letter) appears to reject the CCC’s advice, arguing that: “The exclusion of international aviation and shipping emissions in the UK’s carbon budgets and 2050 emissions target is consistent with the Paris Agreement, which looks to the International Civil Aviation Organization (ICAO) and the International Maritime Organization (IMO) to develop targets”. There will be no immediate change to UK policy or law, the paper indicated, though the Government is “minded to include these emissions in domestic legislation at a later date, subject to future progress in the IMO and ICAO” (p90).
CCC’s Chief Executive has since argued that this shouldn’t be interpreted as a formal response to the Committee’s detailed letter on aviation and shipping, and that the Government was simply restating prior positions which may yet be reviewed. In particular, he said, the Government has indicated that it will shortly update its position of aviation and climate change when it publishes the final aviation strategy. This had been due out by the end of this year but has been delayed, partly by the election, but also to allow for further public consultation on the sector’s climate change impacts. We anticipate this consultation being published in the new year.
CCC has tried to draw a distinction between the inclusion of aviation in carbon accounts (which should happen at the national level, it argues), and the design of measures to control emissions (which should, CCC argues, be primarily international). Keeping the two separate could require some extra bureaucratic legwork. If aviation emissions were included in carbon accounts, we would need to resolve, for example, questions about whether airlines’ participation in CORSIA and/or or EU ETS would be regarded as carbon reductions in the UK’s account. But with the CCC having made clear that the UK’s net zero target should be met through domestic action rather than by way of international offsets, these complications may only be temporary, with carbon markets becoming less relevant over time as all sectors move towards net zero emissions.
Scotland is, to our knowledge, the only country so far to have explicitly included its share of international aviation emissions in national climate legislation, though we understand that France and Germany are currently considering whether to follow suit. Including these emissions in NDCs (Nationally Determined Contributions), which signatories to the Paris Agreement are required to prepare, would have a similar effect to inclusion in national climate legislation, and the fact that most of these commitments don’t yet include IAS has been criticised by Greta Thunberg during the December climate talks in Madrid.
Delivering the Paris Agreement requires a rapid global shift to net zero emissions across all sectors. When it comes to aviation, there are strong reasons for the UK to take the lead. Our climate law and system of carbon budgets are now well established, so it would be relatively easy to include IAS emissions. And British people do a lot of flying. In 2018, British passport holders took more international flights than travellers of any other nationality. With the UK hosting next year’s climate summit, and our own climate commitments likely to come under scrutiny, it’s surely time to start taking responsibility for the impact of our flights on climate change. We should of course continue, in parallel, to advocate through the UN for effective action on aviation emissions, but it is clear that on its current path, ICAO won’t bring aviation into line with the Paris Agreement without additional action being taken.
A combination of behaviour change around flying, technology improvements, zero carbon fuels and carbon removals could deliver net zero aviation by 2050, but this won’t happen without mechanisms to hold the industry to account. Let’s hope 2020 will be the year we see it happen.