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ROYAL COMMISSION ON ENVIRONMENTAL POLLUTION NEWS RELEASE
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April 2001
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| RESPONSE BY THE
ROYAL COMMISSION ON ENVIRONMENTAL POLLUTION TO GOVERNMENT'S
CONSULTATION ON AVIATION |
INTRODUCTION
| 1. |
The Royal Commission on Environmental Pollution has a strong and
longstanding interest in the environmental impacts of aviation. Its
First Report in 1971 (Cmnd 4585) warned that it would be
‘dangerously complacent’ to ignore the potential implications for
the local and global environments from the increasing number of
commercial flights. Since then, the expansion of air transport has
brought many economic and social benefits. The scale of growth has
been enormous, and is projected to continue. |
| 2. |
The Commission’s Eighteenth Report, Transport and the
Environment (Cm 2674), published in 1994, included a chapter on
air transport. It saw:
a powerful case on environmental grounds for regulatory action
to avert what could be irreversible damage to the Earth’s
atmosphere from the growth of air transport, or at least serious
damage of a long-term nature (5.33).
The Commission concluded that:
an unquestioning attitude towards future growth in air travel,
and an acceptance that the projected demand for additional
facilities and services must be met, are incompatible with the aim
of sustainable development (5.39). |
| 3. |
The Eighteenth Report made a series of recommendations
(reproduced here in an annex)
to reduce the environmental impacts of aviation, including a call
for a tax on aviation fuel. The Commission is profoundly
disappointed that there has never been a government response to
those recommendations. |
| 4. |
Since publication of the Eighteenth Report, the case for strong
international action to prevent climate change from running out of
control has become even more compelling. The Commission’s
Twenty-second Report, Energy - The Changing Climate (Cm
4749), published last year, called on the UK to take a lead role in
international negotiations to combat climate change. |
| 5. |
To underpin that, it recommended (10.10) that the government
should adopt a strategy which will put the UK on a path to reducing
carbon dioxide emissions by some 60% from current levels by about
2050. The Commission made clear that radical changes would be needed
in all sectors of the economy in order to deliver emission
reductions on such a scale. |
| 6. |
It recognised that the predominantly international nature of the
aviation industry makes it difficult for the UK or the European
Union to act unilaterally in restraining the growth in emissions.
The Commission urged the government to press for an international
tax on aircraft fuel; or, if that proves impossible to achieve by
2010, to press for a fuel tax or climate change levy at OECD or EU
level (6.131). |
| 7. |
We welcome the opportunity to respond to the government’s
consultation document. This statement deals with aviation’s impacts
on the global environment, and climate change in particular, because
we consider these represent an overarching constraint on the future
growth of air transport. These global impacts are associated chiefly
with the carbon dioxide, oxides of nitrogen and water vapour emitted
by aircraft. We fully recognise the importance of tackling the local
environmental impacts associated with airports, including air
pollution, noise, urbanisation and surface transport links. We hope
our next report, on environmental planning, will shed light on the
general issues that arise in assessing and controlling impacts of
that nature. |
| 8. |
This response addresses the main questions raised in the
consultation document, not the more detailed questions on
environmental issues. Air transport is a strong candidate as the
subject for a future Commission report. This response gives an
outline of the Commission’s current views, without prejudice to the
outcome of any future study. |
ANSWERS TO QUESTIONS
QUESTION 1: Should the government choose policies that
respond to the demands of consumers and allow current growth patterns to
continue, while mitigating the negative effects as far as possible? Or are
the costs of this approach too high and should we therefore choose
policies to limit these negative effects?
| 9. |
The Royal Commission is concerned that the government’s
consultation document fails to recognise the magnitude of the threat
posed by climate change. The latest assessment by the
Intergovernmental Panel on Climate Change (IPCC) gives the clearest
warning yet that most of the observed warming in the Earth’s climate
over the last 50 years is ‘likely to have been due to the increase
in greenhouse gas concentrations’. The IPCC projects that, on
current trends, global average temperatures will increase by
1.4-5.8°C by 2100 - this would cause changes in climate which pose
huge challenges to human societies and ecosystems around the world.
Moreover, by continuing to release greenhouse gases into the
atmosphere mankind is committing the world to even greater global
warming and climate change beyond that date. |
| 10. |
The Commission’s Twenty-second Report proposed that
international efforts to control climate change should regard an
atmospheric concentration of 550ppmv of carbon dioxide as an upper
limit that should not be exceeded. This figure makes optimistic
assumptions about the success of actions to limit other greenhouse
gases. It represents a doubling of the pre-industrial level - and
would still commit the world to significant long-term changes in
climate and sea level. |
| 11. |
To achieve this goal, global carbon dioxide emissions, which are
at present rising rapidly, will have to fall dramatically, to about
30% of present levels in the long term. The Commission concluded
that developed countries would need to make a still greater
contribution. For the UK, carbon dioxide emissions would need to be
cut by some 60% by 2050 and by 80% by 2100. Even if a much riskier
objective were set for atmospheric levels of carbon dioxide, the UK
would still need to reduce emissions by more than 40% over the next
half-century. |
| 12. |
Moreover, the Commission is concerned that the consultation
document significantly misrepresents the importance of aviation’s
growing contribution to climate change. The document cites the
IPCC’s recent report on Aviation and the Global Atmosphere to
suggest that the contribution made by aircraft to human-induced
climate change will increase from 3.5% in 1992 to 3-5% in 2050. This
presentation assumes that total global emissions resulting from
human activities will continue to grow in line with the IPCC’s
scenarios for 2050 - these mostly imply severe and unacceptable
environmental consequences. As explained above, total global
emissions - and especially the contribution from developed nations -
must be reduced significantly below present levels if the risk of
catastrophic climate change is to be averted. |
| 13. |
In the context of the consultation document, the most important
indicator is the absolute growth in aviation’s contribution
to global warming. The IPCC expects the contribution from subsonic
aircraft in 2050 to increase to between 2.6 and 11 times the level
in 1992. On the mid-range scenario, the contribution of subsonic
aircraft will increase almost four-fold. Moreover, the IPCC warns
that development of a second generation of supersonic civil aircraft
could lead to a further increase in the total global warming effect
from aviation of about 40% in 2050, mainly because of the
accumulation of water vapour in the stratosphere. |
| 14. |
Such a growth in aviation’s contribution to global warming is
extremely difficult, if not impossible, to reconcile with the need
to make demanding overall reductions in greenhouse gas emissions
over the next few decades. |
| 15. |
Clearly, it would be unreasonable to expect every sector of the
economy to make identical reductions in emissions. Options such as
emissions trading, discussed below, could offer a framework to
accommodate a relatively high level of emissions from growing
sectors such as aviation. However, it should not simply be assumed
that other sectors will be willing or able to make more stringent
emissions reductions to compensate for the forecast increase in
emissions from aviation. The Commission’s Twenty-second Report made
clear that large emission reductions can be achieved in all sectors
of the economy, but not without significant costs and formidable
barriers. The Commission is therefore concerned that any
significant medium-term growth in aviation’s contribution to global
warming is incompatible with the need to make demanding reductions
in total greenhouse gas emissions, globally and particularly by the
developed nations. |
| 16. |
It is important to recognise that the IPCC’s scenarios already
assume a significant improvement in fuel efficiency of aircraft (by
40-50% by 2050) and full implementation of improvements in air
traffic management. These factors are overwhelmed by a predicted 5%
a year growth in global air traffic. Moreover, measures to improve
fuel efficiency may increase emissions of nitrogen oxides which also
contribute to global warming. More radical changes in technology may
be counter-productive: for example, converting aircraft to hydrogen
fuel is likely to increase the warming effect caused by water vapour
and condensation trails in the upper atmosphere. These factors
suggest that there may be limited scope for technical improvements
to further reduce aviation’s impact on global warming. The
Commission concludes that aviation policy must not simply respond to
current growth patterns. A primary aim of policy must be to seek to
limit aviation’s contribution to global warming. This will require
significant constraints on the growth of air traffic. |
| 17. |
The government’s aviation strategy is intended to set the policy
framework for the next 20 years. Over the same timescale, the UK and
the developed world will need to make progress towards a low-carbon
economy. The Commission’s Twenty-second Report noted that decisions
on infrastructure such as power stations and roads commit society to
a particular emissions path for many decades. The same principle
applies to airports. There is a danger that short-term pressures to
accommodate growth in air transport could lead to decisions on
infrastructure which will undermine future efforts to limit the
sector’s contribution to global warming. |
| 18. |
The DETR’s forecast growth in air traffic could not be met
without significant new airport capacity in the UK. Whether this is
met at new sites or by extension of existing airports, there are
likely to be significant increases in noise, air pollution,
urbanization, land take and landscape impacts. Restraining the
growth of air traffic would yield corresponding benefits to local
environments. In pursuit of sustainable development, the
government has accepted the need to move away from a ‘predict and
provide’ approach in areas such as road transport, minerals planning
and housing. The same logic must now be applied to
aviation. |
QUESTION 2: How should the government ensure that aviation meets
the external environmental costs for which it is responsible? Should
greater emphasis be placed on regulation (at global, national or local
level), economic instruments or voluntary agreements? If we should use a
mix of approaches, what are the principles that should underlie the choice
of approach for each issue?
| 19. |
The Commission welcomes the statement in the 1998 Transport
White Paper (Cm 3950) that aviation should meet the external costs
it imposes, including environmental costs. Nevertheless, it must be
recognised that there are formidable practical difficulties in
applying this principle; we discuss this topic more fully in
answering Question 3. The primary aim should be to design policy
instruments that will deliver a desired objective. In the case of
aviation, the aim should be to achieve a significant reduction in
its forecast contribution to climate change. This is essential to
achieve long-term environmental sustainability and to ensure that
uncontrolled climate change does not jeopardise long-term economic
and social development. |
| 20. |
Clearly, the global nature of the climate change issue and the
international nature of the aviation industry mean that any
effective action to constrain growth and reduce emissions must be
taken internationally. However, this should not be regarded as an
excuse for inaction at UK or EU level. The approach we are
advocating will only succeed if it is championed effectively at
international negotiations. The introduction of EU-wide taxes on
aviation fuel or a climate change levy on landing fees, for example,
could strengthen the EU’s negotiating position and leadership role
within the International Civil Aviation Organization (ICAO). |
| 21. |
The Commission’s Twenty-first Report, Setting Environmental
Standards (Cm 4053), concluded that self-regulation and the use
of economic instruments should be regarded, not as alternatives to
direct regulation, but as complementary to it. While economic
instruments are not a panacea, and administrative controls may be
required as well, economic or financial incentives should be used
wherever possible to reinforce the effect of direct
regulation. |
| 22. |
There is a clear role for regulation, for example in setting
demanding, technology-forcing standards for fuel efficiency of
aircraft at all stages of flight. |
| 23. |
The drive to develop more fuel-efficient aircraft could be
reinforced by market-based options such as environmental levies and
emissions trading. These could also, if designed appropriately, help
to constrain the growth in air travel and encourage transfer from
short-haul routes to less polluting modes of transport. Some
two-thirds of international flights from the UK are to Western
Europe. For many of those journeys, and for many domestic flights,
use of alternative modes such as high-speed rail would make a much
smaller contribution to global warming. |
| 24. |
There are strong environmental grounds to introduce taxation on
aviation fuel. Fuel used in other modes is subject to taxation,
often at a fairly high level: the lack of taxation of aviation fuel
is therefore a perverse signal. Other forms of taxation are
available, such as a climate change levy on landing fees or air
passenger duty. In the March 2000 Budget the Chancellor announced a
halving of the air passenger duty for economy flights from the UK
within Europe. The Commission regards this as a retrograde step
which sends entirely the wrong price signal. |
| 25. |
The Commission’s Twenty-second Report called on the government
to press for an international tax on aircraft fuel while
maintaining or increasing its own taxes on aviation. If, as seems
likely, global agreement proves impossible in the current decade,
the government should use its best efforts to secure an OECD
aviation fuel tax or, if that also proves impossible, a harmonised
climate change levy on landing fees. Either of these could be
applied solely within the European Union if a wider agreement cannot
be negotiated. The revenues raised by such taxes would be
distributed among national governments for them to spend as they saw
fit, but a proportion might go into a collaborative fund to support
international projects addressing the threat of climate
change. |
| 26. |
The DETR’s passenger forecasts suggest that the growth in
aviation is highly responsive to price signals. Indeed, the rapid
recent growth in air passenger numbers has been fuelled by the
expansion of scheduled low cost carrier services. |
| 27. |
The central scenario in the DETR’s forecasts, which assumes a 1%
a year decline in average fares over the next 20 years, suggests
that the number of passengers using UK airports will rise from 160
million in 1998 to 401 million in 2020. The forecasts also model the
effect of a global environmental tax of 10% introduced in 2006 and
rising steadily until fuel costs essentially double by 2015. The
effects of this measure are rather limited - the number of
passengers in 2020 would be reduced by only 10% to 361 million. The
main reason is that fuel costs account for only a small proportion
of the fares paid by passengers, and average fares would still
therefore continue to decline. |
| 28. |
If the growth in demand for air transport is to be constrained
to any significant degree by economic instruments, the key factor is
the level of fares. DETR’s forecasts suggest that simply freezing
fares at the current level would reduce the number of passengers in
2020 by 25% to 301 million. This still represents an increase of
nearly 90% on 1998 levels. In light of the environmental
imperatives outlined above, any tax or levy on aviation should be
set at a level sufficient to ensure that the average fares paid in
real terms by passengers remain at, and preferably rise above, the
present level. |
| 29. |
Emissions trading offers a complementary market-based approach
to managing the impact of aviation on climate change. In principle,
it could offer an economically efficient way of sharing out emission
reductions both within the aviation sector and between aviation and
other sectors. |
| 30. |
The United Nations Framework Convention on Climate Change covers
international aviation. Article 2(2) of the Kyoto Protocol requires
Annex 1 parties to pursue limitation or reduction of emissions from
aviation, working through ICAO. However, emissions from
international aviation are not included in the targets for reducing
emissions set by the Kyoto Protocol. |
| 31. |
If the international aviation industry is to participate in
emissions trading with other sectors or with nation states, that
must be within the overall framework of international agreements on
reducing emissions of greenhouse gases. The industry will have
to be given its own binding emissions ceiling, set at a demanding
and declining level, in order to provide the incentive for trading
and drive meaningful reductions in emissions. |
| 32. |
If the aviation industry proceeds with a carbon offset or
emissions trading scheme of its own, great care must be taken to
ensure that real net emission reductions result. If the industry
supports renewable energy, energy efficiency or carbon sequestration
schemes to offset its own growth in emissions, there is a danger
that the resulting emission savings will be double-counted as part
of the host nation’s commitments under international law. Rigorous
methodologies will need to be developed to prevent such an
outcome. |
| 33. |
Voluntary agreements may well have a useful role in mitigating
some of the local environmental impacts of aviation, such as noise.
However, it is doubtful that they could be robust enough, or have
sufficient scope, to deal with the fundamental problems posed by the
need to reduce aviation’s impact on global warming. |
| 34. |
Another option to constrain the growth in aviation would be to
limit the growth in airport capacity to less than would be required
to meet the forecast demand. There may be a case for pursuing this
approach in order to deliver local environmental benefits. However,
if unsupported by other economic or regulatory measures, there may
be limited global environmental benefit. There may also be a
damaging effect on the UK’s international competitiveness if other
countries in Western Europe expand their capacity to make up the
shortfall. These concerns underline the need for the UK to drive for
a concerted approach at EU level towards curbing the growth in air
traffic. |
QUESTION 3: If aviation covers its environmental costs, should
capacity then be provided to meet demand?
| 35. |
If it were clear what value should be placed on the external
effects caused by use of a product, that might in theory indicate
the appropriate rate at which to tax the product. If tax were
imposed at that rate, the socially optimal quantity of the product
could be regarded, in broad terms, as the amount consumers then
chose to use. |
| 36. |
In practice, it is not easy to design and introduce corrective
taxes in this way. The value that should be placed on an external
effect may not be obvious, and long-term effects such as the impacts
of climate change may be particularly difficult to value in monetary
terms. These problems are compounded where there are large
uncertainties in the nature, location and timing of the impacts, as
is the case with climate change. |
| 37. |
The difficulties associated with evaluating and internalizing
environmental costs are illustrated by the DETR’s pamphlet
Valuing the External Costs of Aviation. This puts forward
only illustrative figures for the environmental costs imposed by
noise and climate change. The pamphlet accepts that as yet there is
insufficient supporting literature to even attempt to value other
important impacts of aviation, including local air pollution,
landscape, biodiversity, heritage and water. Furthermore, the
pamphlet accepts that the environmental costs attributed to noise
and climate change are ‘illustrative and subject to high levels of
uncertainty’. |
| 38. |
The pamphlet puts the environmental costs associated with noise
and climate change at around £3 per passenger on shorthaul
operations and £20 per passenger on longhaul aircraft. If these
costs were passed on in full to passengers, shorthaul fares would
increase by 3.5% and longhaul fares by about 5%. Demand for
shorthaul and longhaul travel would be reduced by just 3% and 5%
respectively - broadly equivalent to the forecast growth in a single
year. |
| 39. |
It is clear that internalizing the environmental costs as
identified in the DETR’s pamphlet would make almost no discernible
difference to the predicted growth in aviation and the associated
impact on climate change. Indeed, some in the aviation industry are
using the figures in the pamphlet to claim that aviation already
meets its environmental costs through air passenger duty, and that
no constraints on growth are necessary. |
| 40. |
We are concerned that such an analysis fails to acknowledge the
severe medium- and long-term implications of climate change. The
difficulties and uncertainties involved in agreeing monetary values
for many environmental impacts mean that an approach based only on
internalizing environmental costs is difficult to implement and runs
a high risk of producing an outcome which is environmentally
unsustainable. |
| 41. |
In particular, we are not convinced that the environmental costs
attributed to emissions of carbon dioxide and other greenhouse gases
fully reflect the long-term damage which unabated human-induced
global warming threatens to cause to the environment, and
consequently to social and economic development. The Commission’s
concerns are developed fully in its Twenty-second Report, Energy
- the Changing Climate (see 4.21-4.28). |
| 42. |
Instead, the Commission advocates a more pragmatic approach to
deciding on an appropriate long-term response to the threat of
climate change. As explained above (paragraph 10), the Twenty-second
Report identified an atmospheric concentration of carbon dioxide
beyond which severe and unacceptable environmental effects become
increasingly likely. It acknowledged that limiting the concentration
of carbon dioxide in the atmosphere would entail significant
economic costs, but concluded that these would be ‘a reasonable
price to pay to reduce the environmental dangers’. |
| 43. |
Policies should be designed to ensure that the environmentally
sustainable objective is reached in the most cost-effective way,
through a combination of regulatory and economic instruments. To
deliver the objective, every sector - including aviation - will need
to change its forecast emissions trajectory to a significant degree.
Policymakers must recognise that although air transport is at
present a relatively minor contributor to human-induced global
warming, the forecast rapid growth could jeopardise society’s
efforts to prevent climate change from running out of
control. |
Steel House, Westminster
April 2001
Top
ANNEX
KEY CONCLUSIONS AND RECOMMENDATIONS ON AIR
TRANSPORT IN THE ROYAL COMMISSION’S EIGHTEENTH REPORT, TRANSPORT AND
THE ENVIRONMENT (Cm 2674)
International air traffic has been increasing even more rapidly than
road traffic, there are major question-marks over its environmental
impact, and effective regulation must be undertaken on a global basis. We
attach particular importance therefore to the recommendations we make
about the international measures to limit the environmental effects of air
transport (14.100).
The issue of most concern is the potential effect of high altitude
emissions, especially of nitrogen oxides, on the Earth’s atmosphere. We
recommend that the government press for the extension of the regulatory
role of the International Civil Aviation Organization to cover emissions
from aircraft at all phases of flight, with the aim of protecting the
Earth’s atmosphere against irreversible or long-term changes (5.34).
We recommend that the government negotiate within the EC, and more
widely, for the introduction of a levy on fuel purchases by airlines that
will reflect the environmental damage caused by air transport (7.75).
Of all forms of transport, aircraft produce the greatest intensity of
noise. Although improved engine design has reduced the number of people
exposed to very high levels of noise, the expansion of regional airports
and growth of traffic have placed the majority of the population within
earshot of aircraft. We recommend that the government implement the
Batho Committee’s recommendation for a noise levy on movements at airports
(7.76). We recommend that the government support more stringent noise
certification standards for new aircraft, if these can be met without a
significant fuel penalty (5.35).
Deregulation of airlines in the USA in the 1980s led to increased
emissions per passenger-kilometre because load factors dropped and smaller
aircraft were used. We recommend that proposals for further measures to
promote competition in air services in Europe be accompanied by a full
assessment of the environmental implications (5.40).
Government policy should be based on transferring as much traffic as
possible from air to rail. We recommend that policy on air services
should be based on discouraging air travel for domestic and near-European
journeys for which rail is competitive, and that the government should
support the upgrading of rail links to the main international airports in
order to avoid the need for development of air feeder services from
regional airports (12.50).
We recommend that the UK collaborate in research into the possible
effects of supersonic aircraft on the stratosphere and ways of minimizing
those effects (including the possible imposition of route restrictions in
relation to latitude and altitude), so that a comprehensive environmental
assessment can be produced and considered on an international basis before
decisions are taken to build and operate a new generation of commercial
supersonic aircraft (5.37).
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