16th July, 2021
The Government’s long-awaited proposals for delivering net zero aviation by 2050 were published this week alongside the Transport Decarbonisation Plan and a number of other documents. The aviation policy is open for consultation until 8th September. Proposals for a mandate on the use of Sustainable Aviation Fuels are expected shortly.
AEF and others had been calling for a different approach to aviation as the UK emerges from the pandemic. The key phrase from ministers on Wednesday, however, seemed to be that in future we would be ‘doing the same things differently’. In a written ministerial statement Grant Shapps announced that in future “We will still fly on holiday, but in more efficient aircraft, using sustainable fuel… We will still have new development, but it won’t force us into high-carbon lifestyles.”
There are aspects of the plan that are welcome. The proposal to decarbonise domestic flying by 2040 is a good, and potentially deliverable, ambition, albeit that domestic flights account for only 4% of total UK aviation emissions. Plans to set gross and net emissions reduction trajectories to track progress towards 2050, with 5 year strategy reviews, are sensible, though no measures have been proposed to rein in emissions if they turn out to be higher than hoped. And we’d support the proposals to consider mandating the provision of CO2 information to passengers (by route and class, at the time of booking) and to strengthen carbon pricing in line with the ‘polluter pays’ principle. Both of these steps could have an indirect impact on demand through changing social attitudes, and higher ticket prices.
But while these initiatives help to frame a policy discussion, the proposed measures to decarbonise the sector fall a long way short of the scale of the challenge ahead. UK aviation emissions reached a record high in 2019. As other parts of the economy have been decarbonising, aviation emissions have continued to grow, and an increasing number of organisations, including the CCC (the Government’s official climate advisers) as well as numerous independent analysts (ranging from the UK FIRES academic coalition to the IEA) have concluded that getting aviation emissions to net zero by 2050 will require limits on demand growth and quite possibly a reduction in flying.
The Government “believes”, by contrast, that the aviation sector can achieve “Jet Zero” without the need for direct intervention to limit demand. As the basis for this, it has developed scenarios “focussing on new fuels and technology”. While not commenting explicitly on CCC’s recommendation (set out in its Sixth Carbon Budget report and in its recent progress report to Government) that it should rule out any net increase in airport capacity, the Government’s modelling assumes that airports continue to grow in line with their pre-pandemic plans.
Despite allowing for this growth, however, the Government claims that its preferred “high ambition scenario” would see in-sector CO2 emissions fall from 39 Mt in 2030 to 31 Mt in 2040 and 21 Mt in 2050 (with residual emissions in 2050 assumed to be offset by greenhouse gas removal methods). What confidence can we have, then, in the assumptions made in this pathway?
At an overall level, “many of the technologies we need are in their infancy and will take time to develop”, the Government says. Nevertheless, average fuel efficiency is assumed to increased to 2% per annum between now and 2050, compared with 1.5% per annum based on current trends. The only new proposals to help deliver this significant increase in aviation technology improvement, however, are to seek a voluntary agreement from airlines to avoid tankering fuels, and to aim for all airport operations (principally buildings and ground vehicles) to be zero emissions by 2040. No costs are modelled for the more rapid introduction and accelerated uptake of new technologies.
On fuels, the Government’s model assumes 30% of total aviation fuel by 2050 to be ‘sustainable aviation fuel’ (compared with 5% on current trends), and that such fuels will deliver a 100% emissions reduction. It admits however that “current SAF use in UK aviation is negligible and there is significant uncertainty around the availability and cost of SAF in the future.” The approach to carbon accounting for many SAFs is highly questionable, meanwhile, and while some fuels, the Government claims, can reduce emissions by more than 70% on a lifecycle basis, almost none yet exist that can deliver a 100% reduction.
The application of a carbon price is the only measure that’s included in the model that is assumed to dampen demand. A price increasing to £230/tonne of CO2 is assumed to apply to all flights, despite this being ‘not reflective of the current policy landscape’ as CORSIA – the only carbon pricing mechanism currently in place to cover flights that land outside Europe (those responsible for the majority of emissions) is due to end in 2035 and will apply only to emissions above a 2019 baseline (a level unlikely to be reached globally until at least 2024).
Finally, to balance the 21 Mt CO2 that the DfT anticipates still being emitted annually by airlines by 2050, the consultation notes that ‘greenhouse gas removals’ will be needed but that “GGRs are not yet implemented at commercial scale, either in the UK or globally, and forecasts of costs and scale-up potential are highly uncertain”. Proposals on the Government’s approach are promised in future.
AEF will be preparing a response to the consultation. There are some promising ideas here. But we’re deeply disappointed that the Government has failed to grasp the nettle in terms of the overall direction that the industry needs to take. Technology ambition is essential, but without a plan to make sure it’s delivered, or that the industry pays for it, what confidence can we have that the industry will rapidly step up the pace? And while we recognise the uncertainty about which of those technologies will succeed and which will fail, for the Government to remain relaxed about growth in both passenger numbers and potentially airport capacity will allow the aviation emissions problem to worsen while we wait and see, and that feels like a betrayal of the promise to build back better.