RAS ZAS0023
1.1 The Royal Aeronautical Society is the only global organisation serving the entire aerospace, aviation and space community as both a learned society and a professional engineering institution. As such, the Society is independent, evidence-based and authoritative, relying on a body of knowledge going back more than 150 years. The Society plays a leading role in influencing opinion on aerospace aviation and space matters, through various means, including its publications, social media profile, interaction with government and an extensive events programme.
2.1 The committee’s inquiry covers aviation and shipping. We will confine our evidence to aviation.
2.2 In common with other professional bodies, the RAeS is bound by a code of ethics which is mandatory for all our members to agree to and abide by. It will be very important for the aviation industry that the targets it adopts and the reporting of achievements towards the targets are completely transparent and auditable, and the responses below are drafted with those principles in mind.
3.1 We are strongly supportive of the government’s aim to achieve net zero aviation by 2050 and net zero domestic aviation by 2040. Not only do we need to take bold steps to address climate change but these objectives will help the UK to protect and grow its world leading aerospace and aviation industries, increase its share of the market and grow its position in the value chain.
3.2 Achieving the objective will be tough and must be supported by government and private investment, especially over the next 10 years. Early investment in relevant technologies will also help the sector to recover from the pandemic and place it in a strong position over the next two decades to secure value from new opportunities in important areas, such as next-generation single-aisle aircraft, Urban Air Mobility (UAM) and dual use technology that reads across to broader civilian and defence capability.
3.3 For general aviation, consideration needs to be given to the longer average lifespan of light aircraft in private hands and the very small part of the overall aviation emissions total to which private aviation contributes. Some provision should therefore be made for a more gradual phasing out of fossil fuel-powered light aircraft and the continued operation of veteran and vintage aircraft. That said, the operational and technical aspects of general aviation lend themselves easily to zero emissions flight.
3.4 For domestic commercial operations, the net zero target can be achieved by the imposition of net emissions limitations on internal flights, by the rapid modernisation of UK Airspace and Air Traffic Management systems to ensure optimum aircraft routing to minimise fuel usage. Further initiatives would include the mandating of emission reduction measures on the ground through technology, such as electric taxiing, cockpit information systems to inform aircrew of optimum aircraft configurations and general operation for minimum emissions.
3.5 We would be in favour of legally precluding any domestic commercial flights taking place unless either the flight is zero emissions (electric), or any remaining emissions are 100% offset (debates about the validity of off-setting notwithstanding). This would encourage the industry to speed up research into battery aircraft and ensure manufacturers are provided with a market for their products. Note that legislation on minimum renewable content of Jet A and Avgas would also apply progressively.
3.6 We note that Norway is also aiming for a similar commitment in respect of domestic aviation by 2040[1].
3.7 We note the government’s currently open Jet Zero consultation.[2]
3.8 The government’s high ambition scenario should be a baseline but we note that this cuts in-sector emissions by less than 50%.
3.9 We support a combination of scenarios 3 and 4. The UK should be aspiring to achieve breakthroughs in both SAFs and zero emission aircraft; this will maximise the chance of reaching net zero UK domestic aviation by 2040, position the UK to achieve net zero by 2050 and become a world leader in sustainable technologies. While it is important that the environmental goals remain paramount, the projects have to matter economically if they are going to deliver material environmental benefits.
3.10 It is recognised that these scenarios pose very many serious issues which will require a lot of effort to overcome, but so do scenarios 1 and 2 which require massive abatement outside the sector. This will be very expensive, present many technical challenges around DACS technology, and may not be achievable because of the shortage of green electricity to power the DACS plants. We do not believe the cost of this aspect of the abatement has been properly reflected in these scenarios, which consequently should show much greater reduction in demand due to increased costs reflecting the (much) higher fares. Net zero scenarios should be about reducing in-sector emissions, rather than assuming vast quantities of CO2 can be removed by DACS. There is no evidence that this is achievable. Considerably more research and development activity is needed both in the UK and globally to address this issue.
3.11 The trajectories laid out by government should be a minimum standard, with levels of ambition, and requisite government support and technical innovation, to achieve greater reductions through UK leadership in SAF, in zero-emission technologies, and through the acceleration of the wider range of efficiency/emission reduction measures compared with today’s forecasts. There is huge potential benefit to UK industry by leading in this area and recouping its investment in this technology by selling its products and services into other sectors, such as road, rail and maritime. UK-based Rolls-Royce is a good example of how this can be achieved[3].
4.1 The government’s Jet Zero consultation document claims (p22) that a significant proportion of the emissions reductions will come from improving the efficiency of its existing aviation system without clearly defining what is meant by ‘efficiency’ in this context. Jet Zero benefits from the ATM/airspace system are unlikely to be delivered without:
4.2 A) A very clear statement of objectives and policies, including National Policy Statements, that directly reference CO2 reductions, rather than trying to deliver an all-encompassing approach that attempts to satisfy all parties in respect of all impacts of aviation. Without this clarity, the CAA, ACOG, ANSPs and airports will lack the necessary tools to deliver their contribution to the Jet Zero targets.
4.3 B) Changes to administrative law that will properly address the right of the public to object to unlawful decisions while preventing actions that are intended to stifle, delay or prevent lawful changes occurring that can deliver a contribution to the Jet Zero targets.
4.4 Nevertheless, improvements in airspace and ATM efficiency can play a part through the implementation of optimised climb and descent profiles, improved approach paths, direct routing using the best available satellite navigation techniques and through monitoring systems that accurately record the environmental impact of each flight profile. Previous attempts to make changes that contribute to some of these goals have foundered due to adverse public reaction, largely to the noise impact that might occur. As such, the airspace efficiency element will be highly dependent upon a number of concomitant changes in the legislative and policy frameworks to make this happen. Renewed focus on environmental issues and climate change, in particular in the post Covid-19 recovery scenario, provide an excellent catalyst to initiate work that will enable real change to be delivered in the next two decades.
4.5 Firstly, the government needs to be very clear in what it is setting out to achieve in this context. Despite the stated intention to set out clear goals, the consultation sets out the potential for short-to-medium-term reductions in CO2 emissions but then in the same sentence links to potential benefits in noise and air quality. Changes in the ATM arrangements are unlikely to deliver win-win solutions in all three categories of CO2, air quality and noise, although there may be some changes that deliver benefits in more than one area. Furthermore, the section related to the CAA’s Airspace Modernisation Strategy focuses on the potential economic benefits to the UK economy and not on carbon reduction. If the focus is to be on emission reductions as a contribution to the Jet Zero targets, then the government should be clear on emission reduction as being the absolute priority, second only to safety. To date, public reactions to proposed changes in airspace arrangements have been more focused on the potential adverse impact of noise than on emissions reduction and it may require significant government effort to adjust this perception.
4.6 Secondly, if this is to be the case then there are changes needed to legislative and policy arrangements in a number of areas. Some of these are under way but the final outcomes are still unclear and if the potential airspace changes referenced above are to be delivered, then these policy changes will need to complete their legislative journey and be translated into policy and procedures that the CAA, ACOG, airports and air navigation service providers (ANSPs) can implement in a reasonable timescale with a strong likelihood of successful delivery.
4.7 Thirdly, the policy approach needs to be a holistic one and not a repeat of the piecemeal approach that has been used in the past with limited success. This means that airspace issues need to be considered within the widest context and outcomes should be driven by the 2 overriding objectives of safety and emissions reduction. Such an approach will need to take into consideration the needs of all airspace users, including the military, and those members of the public on the ground that may be impacted by aviation activity in all its forms. However, what does appear to be clear in this context is that it is simply not possible to please all of the parties all of the time and deliver a significant reduction in CO2 emissions. Hence the government should be very clear on its policy objectives in this regard, otherwise the CAA, ACOG, airports and ANSPs will face the same difficulties that have arisen in the past.
4.8 Some small operational changes could be useful in reducing aviation’s climate impact. Examples include:
4.9 Review noise abatement procedures to enhance fuel efficiencies and improve aircraft performance. While various factors make flying ‘perfect green flights’ very complex, a lot can be done to make flights greener at every stage of a journey. For example, where possible, use the ICAO NADP 2 vs NADP 1 (Noise Abatement Departure Procedure).
4.10 During the approach, flap and gear extension might be delayed beyond the current practice, given some slight changes to gear warning systems.
4.11 Prohibit economic ‘fuel tankering’, whereby aircraft carry more fuel than they need to reduce or avoid refuelling at their destination airport. Carrying excess fuel has an environmental impact as the weight of the fuel itself increases fuel burn[4].
4.12 Displaying the Targeted Start-up Time (TSAT) on the ground enables aircraft to taxi to their departure runway in the shortest time possible and reduces waiting times.
4.13 Better, fuel-optimised flight planning, including arrival sequencing at congested hubs would reduce holding.
4.14 Changing the taxation regime to better reflect an individual’s contribution to climate change.
5.1 The Climate Change Committee has made it clear in reports that biomass/biofuels will be limited in their applicability if they are not to impact biodiversity or drive adverse economic behaviours, such as loss of forestation or overuse of limited water resources. To deliver the necessary volumes of SAF to support net zero aviation operations requires large volumes of green (NOT blue) hydrogen, and the scaling up of power-to-liquid plants, with the accompanying increase in availability of green electrical power, significantly beyond the levels envisaged in the UK Hydrogen Strategy. Total availability of green energy (electricity or hydrogen) will therefore be a limiting factor in the success of the Jet Zero ambition.
5.2 We note the separate current consultation on SAF mandates. We urge the government to work with ICAO and the EU to coordinate any mandates across borders so as to ensure a level playing field and so that carriers cannot undercut each other on the basis of the level of SAF mandated by their governments.
5.3 There is real opportunity for the UK to take a lead in the transition to net zero aviation, only part of which will be achieved through having a strategy. Execution of the strategy will require increased investment in STEM at schools and in universities to grow the generations of skilled scientists, engineers, and operators to populate the UK aerospace industry, including new innovative start-ups, and then direct funding of technology programmes in ways which provide a predictable context to catalyse private investment in key net zero and zero emission technologies such as SAF, hydrogen-fuelled propulsion, highly efficient wing and airframe design and others. The announcement of no new programmes being funded by ATI for FY2021/22 has a highly negative impact in this regard.
6.1 Carbon markets are a very questionable way of driving down CO2 emissions in the long run and are unlikely to survive increasing social scrutiny as the effects of climate change manifest themselves over time. Greenhouse Gas removal methods are still immature and do not exist at anything like the scale required to match the likely carbon generation of aviation without substantial acceleration of current ambition. Given the residual carbon emissions in the government’s projections (more than 50% of today’s emissions in the ‘high ambition’ scenario), GHG removal will have to be a significant part of the solution. To achieve this, it is essential to agree a tightening of the existing CORSIA scheme and a much tighter replacement scheme operative from 2035 that is consistent with the 2050 net zero target.
7.1 This is an area where the RAeS has taken significant interest[5]. The non-CO2 climate impacts of flying are as important as those from CO2. The policies set out in the government’s consultation could be much more ambitious. Reducing contrail impacts of flying could happen over much shorter timescales than the ramp-up of significant SAF and/or technology developments. Reducing contrail climate impacts is one of the most cost-effective ways of reducing anthropogenic climate impacts. The technology and expertise to do this resides in the UK and we need to fund the translation of academic research into practice through demonstration trials. The UK should show global leadership in this area, both in terms of further research and policy execution.
8.1 The strategy is unlikely to succeed without some form of economic measures to level the playing field between the cost of operating net zero or zero emission systems compared with current hydrocarbon fuel prices, probably in the form of carbon taxation. Such taxation regimes will need to be targeted carefully to follow the principle that the polluter pays, while also avoiding making flying the preserve of the wealthy. Thus, it may be that the taxation regime could be reformed, such that long-haul business flying carries more of the burden.
8.2 We support providing consumers with information as to the emissions related to their flights. Although some assumptions will have to be made (such as percentage passenger load which will be unknown at the time of booking). We would urge the government to explore how a package of consumer information on ticket sales can be mandated through ICAO (or IATA).
9.1 A recent series of Global Aviation Summits hosted by Cranfield and ATAG* showed how aviation can become the model for the new world of sustainability: an example of global co-operation across industries, using shared principles, mutual support and determination to work through challenges. COP26 presents an opportunity for the UK to demonstrate how this can be put into practice.[6]
9.2 Future skills – it is vital that this strategy is dovetailed with education strategies to continue to promote STEM education and training from early years upwards[7].
9.3 The Covid pandemic has illustrated the vulnerability of our industry to black swan events, such as future pandemics, increased frequency of severe weather events, international conflicts, internet failures etc. which could disrupt our best laid plans – there is therefore an important need to build in resilience and have contingency plans.
9.4 In light of the likely megacities of the future with enhanced digital connectivity, there is merit in assessing return on investment on whether electric propulsion, Urban Air Mobility (UAM), Electric Vertical Take-off and Landing (eVTOLs) etc, will enable regional connectivity more efficiently than existing networks. However, there remain significant challenges to the greening of larger UAS (circa 25kg and above) due to weight and energy capacity, weight and size of batteries at current technical levels.
September 2021
[1] https://www.greenairnews.com/?p=824
[2] https://www.gov.uk/government/consultations/achieving-net-zero-aviation-by-2050
[3] https://www.rolls-royce.com/innovation/net-zero/decarbonising-complex-critical-systems.aspx
[4] See also https://www.eurocontrol.int/sites/default/files/2020-01/eurocontrol-think-paper-1-fuel-tankering.pdf
[5] See also report from RAeS Conference on non-CO2 climate change impacts https://www.aerosociety.com/news/easy-does-it-for-greener-skies/
[6] Cranfield-ATAG Global Summit Series ‘Re-imagining the Future of Civil Aviation: Digital, Resilient (inc. Biosafe) & Sustainable’, Oct 2020 to June 2021. See: https://www.aerosociety.com/news/digital-resilient-and-sustainable/)
[7] For information see our Cool Aeronautics programme https://www.aerosociety.com/careers-education/schools-outreach/cool-aeronautics/