Possible ZAS0012

Submission by Possible

About Possible:

Possible is a climate action charity working for a zero-carbon society built by and for the people of the UK. Our projects and campaigns prioritise public involvement and positive social impact, as well as cutting emissions. Our work spans decarbonisation of energy, travel and consumption, as well as working with nature and talking about the climate crisis. Our work on transport includes our campaign for a frequent flyer fevy (a progressive tax which increases per flight each person takes in a given time period), running the world’s first project connecting solar power directly to the rail network,[1] the Climate Perks scheme allowing employers to offer their staff additional days of paid leave to travel without flying,[2] and our Car Free Cities project exploring the benefits of a move away from mass private car reliance.

Possible’s director of innovation, Leo Murray, developed the proposal for a frequent flyer levy as a way to reduce aviation emissions without impacting on the majority of UK citizens, who fly once per year or less, or adding additional costs to people’s annual holiday. Our wide research base[3] for the policy includes reports developed with the New Economics Foundation setting out the frequent flyer levy[4] and modelling its ability to fairly and equitably constrain aviation demand.[5] We have published reports explaining the limited potential of electric aircraft to decarbonise flights on timescales that are meaningful for tackling the climate crisis[6] and the role of demand management in aviation decarbonisation pathways.[7] We have also published polling finding that the UK public prefers by a large margin a frequent flyer levy to other policy measures to tackle the climate impacts of air travel.[8] Our recent report into how the UK public approaches international travel choices found that two-thirds of people are willing to consider travelling by train rather than by plane, but action is needed to ensure that train travel is as accessible and affordable as plane travel.[9]

As a charity specialising in areas where ordinary people can have the most impact, we have done a large amount of work on aviation but relatively little on shipping. We are therefore responding to this consultation only on aviation.

Summary:

The government’s recognition of the need to tackle aviation emissions is welcome, but their strategy to achieve net-zero aviation by 2050 is fatally flawed. It relies on undeveloped, extremely expensive or unworkable technologies, and refuses to implement a therefore essential part of the solution: policies to fairly reduce demand for flights.

Our own analysis conducted in 2020 reviewed all credible published net zero pathways which include emissions from international aviation to determine to what extent experts expect demand to be able to grow unconstrained while still reaching net zero goals.[10] Of the 17 scenarios reviewed, 14 envisage that some form of demand management will be required to achieve net zero by 2050; of the remainder, two were not compliant with the Paris Agreement, and only one suggested that aviation could grow unconstrained whilst still achieving net zero by 2050.

The Decarbonising Transport plan and the Jet Zero consultation hope to rely on ‘technofixes’ - as yet undeveloped or unproven technologies - to decarbonise flight and avoid having to implement policies to disincentive flying, particularly for frequent flyers. But their projections for what can be achieved without reducing demand are worryingly over-optimistic, relying on technology “breakthroughs” to overcome hard technical or physical barriers. The government refuses to consider the one measure we know would work, and could be introduced now - fair demand reduction. With just 15% of people in the UK taking 70% of the flights, and half of people not flying at all each year, there’s huge potential to cut aviation emissions by discouraging frequent flying, without affecting the majority of people (71% in 2019[11]) who fly once or less per year. Recent BEIS polling found a majority of people in the UK are in favour of a frequent flyer levy - a progressive tax which increases per flight each person takes - with fewer than one in five people opposed.[12]

A frequent flyer levy is the only fiscal policy measure which is capable of reducing aviation demand in a way which decreases rather than exacerbates existing high levels of inequality in access to flights. New analysis carried out by the New Economics Foundation for Possible finds that other measures, such as an increase to Air Passenger Duty or caps on air traffic movements at UK airports, would disproportionately reduce access to air travel by the UK’s poorer residents - and disproportionately impact jobs at regional airports.[13] The progressive element to the frequent flyer levy, in which aviation tax increases for each additional flight a person takes in a year, is therefore essential in ensuring that aviation tax is viewed as fair and acceptable by the UK public. It would be unfair and regressive for measures to reduce demand to result in fewer flights by the majority of people in the UK, who currently fly once per year or less, rather than the small minority who take most of the flights. Reductions in flying must come first from frequent flyers, and policy measures should be designed to achieve this.

While the government hopes that technofixes will decarbonise aviation, there is no sign of policies to incentivise this, such as a sufficiently high emissions tax to narrow the cost gap between kerosene and efuels. Yet although DfT refuses to bring in progressive policies to reduce demand and make flying fairer, they acknowledge that the costs of new technologies and fuels will reduce demand[14] (unless the taxpayer is expected to pay). Without a progressive tax, relying on increasing aviation costs alone to manage demand will result in the situation the frequent flyer levy aims to prevent: the wealthiest being able to continue flying often in a carbon-constrained world, while ordinary travellers who rarely fly are priced out of the skies.

Responses to consultation questions:

What contribution can operational efficiencies make to reduce emissions from aircraft / shipping vessels and over what timescale could these have an effect on emissions?

In the Jet Zero consultation, the Department for Transport sets out its expectations that efficiency improvements will account for more than a third of the emissions reductions needed for aviation, requiring annual improvements of between 1.5% and 2%. This number is significantly higher than the industry’s own forecasts of a maximum of 1.37%,[15] and ignores the fact that the rate of efficiency improvement is decreasing over time, as further improvements become more difficult.[16] It also fails to acknowledge that, historically, improved efficiency has actually contributed to an increase in overall emissions, as lower resource use has decreased costs and increased demand.[17] The Jet Zero plan has proposed no policy or strategy to overcome this.

While operational efficiencies should of course be maximised, DfT’s projections of the scale of decarbonisation they can provide is far too optimistic. In addition, their policies fail to provide a sufficient incentive for the industry to maximise improvements, which would require legislation and/or a sufficiently high carbon price.

How close are zero carbon fuels to commercialisation for aviation / shipping? How effective will the Jet Zero Council be in catalysing zero emissions technologies? What role should transitional fuels such as alternative hydrocarbon fuels play?

We are concerned that DfT is overly optimistic about the potential to scale up alternative fuels, and the extent to which they can actually reduce greenhouse gas emissions from aviation. The only type of alternative fuel which is genuinely low-carbon (although not necessarily zero emission) is efuel, which involves using renewable energy to capture carbon from the air and combine it with green hydrogen created by splitting molecules of water. This is an intrinsically high-energy and therefore expensive process, which is currently only at proof of concept stage. So far the aviation industry has preferred alternative fuels which are cheaper but much more problematic for the climate, such as biofuels or fuels from waste. But the supply of available waste biomass is small, particularly compared to global kerosene demand, and the systems-level carbon impacts of biofuels offer little, if any, advantage over conventional kerosene. Producing fuel from waste, which contains a large proportion of plastics (which are derived from fossil fuels) means that turning it into fuel and burning it still emits fossil carbon dioxide into the atmosphere. Burning fuels made from waste increases rather than reduces tailpipe aviation emissions, and can only be made to look like an improvement by creative carbon accounting which subtracts avoided methane emissions from waste in landfill.[18]

Even under optimistic projections of the development of efuels, they won’t be able to fulfil more than a small fraction of pre-Covid demand for aviation in time to reach the UK’s net-zero by 2050 target. Policies to equitably reduce demand, while maintaining mobility via affordable, low-carbon surface transport, will therefore still be needed.

What new technologies are there to reduce emissions from aircraft / shipping vessels and how close to commercialisation are they?

There are well-known constraints in developing alternative types of aircraft, with the additional weight of battery storage and volume of hydrogen making it very difficult for them to power planes capable of anything beyond short distances and small numbers of passengers. Even if these barriers could be overcome, it still takes decades to develop and safety test new types of planes and then replace fleets. It is therefore extremely risky to rely on new technologies to decarbonise aviation by 2050 without putting in place demand management measures, and ensuring people can access alternative forms of transport. Negative emissions technologies, whether via bioenergy or direct air capture, are untested at scale and require inputs of land, electricity or chemicals which make it impossible for them to counter the scale of the emissions caused by pre-covid levels of aviation.

How should the Government’s net zero aviation strategy support UK industry in the development and uptake of technologies, fuels and infrastructure to deliver net zero shipping and aviation?

To encourage the development of technologies to decarbonise aviation to the extent possible, fiscal and regulatory measures are required to disincentivise emissions from kerosene, which will need to ramp up over time. With the current low taxes on aviation powered by fossil fuels, the industry has little motivation to move away from its cheapest and easiest source of power. The government has already provided support for the development of new technologies, as well as a generous package of support for the aviation sector throughout the Covid crisis, which came without any emissions reductions conditions attached. Given the competing demands on public funding, and the much higher return on investment in terms of access to transport which is provided by existing, workable and affordable technologies such as electric trains (the lack of support for Eurostar during Covid was a particular missed opportunity), it is not viable for the industry to expect the taxpayer to pick up the costs for expensive technologies such as efuels.

What is the most equitable way to reduce aircraft passenger numbers (e.g. reforming air passenger duty and taxes, frequent flyer levies, bans on domestic flights where trains are available, restrictions on airport capacity)? Are there any policy mechanisms that could reduce our reliance on shipping?

Both fiscal and policy measures exist to reduce demand for aviation, itself the one effective way to reduce aviation emissions within a timescale that is meaningful for avoiding climate breakdown. In terms of tax measures, there needs to be both a progressive tax which increases per flight someone takes or per mile that they fly, in order to discourage the frequent flying which makes up most aviation emissions and more equitably distribute remaining air miles; and a tax which is directly linked to emissions, such as a carbon tax or kerosene tax. We therefore recommend the following:

1. Rather than dismiss a solution to aviation emissions which was recommended by the Climate Change Committee and the Climate Assembly,[19] as the Treasury did in their recent consultation on aviation taxation,[20] the government should consult on the benefits of bringing in a frequent flyer levy or air miles levy and the practicalities of implementation.
2. The government should drop plans to cut or remove domestic APD, and should instead invest in low-carbon domestic connectivity by rail, electric coach etc.
3. Passenger aviation tax should reflect as closely as possible actual emissions from flights, and be differentiated by class and distance of flight, as well as frequency of flying.
4. There should be no reduction in aviation tax, whether as a whole or on individual flights, and the tax regime should move towards both a frequent flyer levy or air miles levy and a tax on kerosene.
5. In addition to bringing in national measures, the government should pursue international cooperation on taxing jet fuel, and seek regional if not international agreement on bringing in a progressive aviation tax.

In terms of non-fiscal measures, we would like to see measures to improve the affordability and accessibility of train travel, along with a movement away from domestic flights for non-PSO routes, and an immediate moratorium on airport expansion.

What further action is needed by the International Civil Aviation Organization and International Maritime Organization to drive emissions reductions? What can the UK Government do to drive international action on emissions?

While international cooperation is essential, the government should not rely on ICAO to achieve this as the organisation has demonstrated a lack of will to reduce aviation emissions and is heavily influenced by the aviation industry, which resists any effective measures. Instead, the UK should seek agreement with other countries on implementing effective measures such as a kerosene tax, for which the European Union has already led the way. Policies such as a frequent flyer levy would also ideally be implemented globally or at least regionally. While we understand the government’s reluctance to act unilaterally to reduce aviation, the fact remains that the UK has exceptionally high per capita rates of aviation,[21] and could and should be leading the way on measures to equitably reduce demand. At present, countries such as France which are taking action to limit domestic flights are showing leadership on reducing aviation emissions, while the UK lags behind.

How effective will the global offsetting scheme for international airlines (ICAO’s CORSIA) and the UK and EU ETS be at stimulating technology improvement and/ or behaviour change to reduce emissions from aviation / shipping?

The CORSIA scheme will do more harm than good and is not an effective strategy to reduce aviation emissions, or promote technological improvements or behaviour change. By providing a cheap, and misleading, get-out clause to avoid to reductions in demand via the use of offsets (which have already been shown not to work[22]), they allow high levels of aviation to continue while creating a convenient fiction that the problem of emissions is being dealt with. The offsets are priced far too low to provide any real disincentive to flying, and the existence of the scheme provides a disincentive to the extremely difficult and expensive work of developing genuinely lower-emissions forms of aviation. The existence of offsets, particularly a “standard” scheme such as CORSIA, is also liable to create a misleading impression among travellers that the problem of their flight’s climate impacts has been addressed and it is therefore fine for people to keep on flying. Even in the minority of cases in which offsetting schemes offer additional forest protection, protecting or planting forests cannot counterbalance the additional atmospheric fossil CO2 or non-CO2 greenhouse gases emitted by planes. Nor can those forests be guaranteed in perpetuity, as recent fires in the Pacific Northwest that destroyed trees planted by US tech companies for offsetting purposes have demonstrated.[23]

Similar problems affect the ETS, with the charges incurred under the scheme being too low to provide a genuine disincentive to kerosene-powered flight. To be effective, emissions need to be priced at a high enough rate to make them prohibitive, and to genuinely incentivise a modal shift to other forms of transport for consumers and investment in lower-emissions alternatives by the aviation industry.

How should the UK define its ownership of international aviation and shipping emissions (i.e. arrivals, departures or both) in order to include them in legislative targets?

It seems sensible for the UK to count departures only in its emissions budgets, to avoid double counting.

September 2021