Sustainable Aviation ZAS0024

Sustainable Aviation response to the Environmental Audit Committee inquiry into “net zero aviation and shipping”

About Sustainable Aviation

Sustainable Aviation (SA) is the coalition of UK airlines, airports, aerospace manufacturers, air navigation service providers plus sustainable fuel producers and other key business partners, committed to cutting aviation’s environmental impact and building a world leading aviation sector.

We welcome the opportunity to provide evidence to this inquiry and would be very happy to support with further written or oral evidence as requested.

Executive Summary

 

 

 

 

 

 

 

 

Our commitment and priorities

UK aviation is targeting at least an overall 15% reduction in net emissions relative to 2019 by 2030, and a 40% net reduction by 2040, with the pace of decarbonisation ramping up as game-changing sustainable aviation fuels (SAF), permanent carbon removals, and new low and zero-carbon technologies – such as electric and hydrogen-powered aircraft – become mainstream in the 2030s. See below:

SA has also committed to update the sector’s Decarbonisation Road Map in 2022 to identify the potential for the latest technological advances in aerospace, sustainable aviation fuels and carbon removal to increase the pace of decarbonisation.

Partnerships are vital
Achieving net zero emissions for UK aviation by 2050 will require ever stronger partnerships between the UK Government, the aviation industry and key low carbon innovation partners. Clear policy and leadership decisions are required today, to ensure that today’s breakthroughs in aerospace technology, sustainable aviation fuels and carbon removal are maximised.

The Jet Zero Council is a welcome step towards achieving this, but it needs to build and strengthen its work over the next few years to guarantee the opportunities available for the UK. To make sure UK aviation continues to lead the world in aviation decarbonisation, further support is needed in six areas critical to realising net-zero flight:

●        Key policies this year to deliver a UK SAF industry and commercialise SAF, most urgently by providing a demand signal and price support – the primer for up to 14 UK plants generating sustainable fuel from household and industrial waste by the middle 2030s, supporting at least a 32% reduction in emissions from UK aviation by 2050;

●        A positive, long-term signal for investment in aerospace technology and the development of hybrid, electric and hydrogen-powered aircraft through increased and extended funding for the Aerospace Technology Institute;

●        The completion of vital airspace modernisation generating significant carbon savings through more efficient flying and shorter journey times;

●        Policies that incentivise the commercialisation of carbon removal technologies that enable carbon neutral or carbon negative aviation fuel, allowing the aviation industry to address any remaining residual emissions;

●        Integrating national energy and jet zero ground infrastructure:  It will be critical to support development and delivery of additional infrastructure on the ground to enable zero emission flight.  This includes integrating national energy policies with Jet Zero policies to ensure there is sufficient electrical and hydrogen generation and supply to airports to support increased demand;

●        UK Government to seek a more robust international commitment for aviation carbon reduction at the ICAO General Assembly in 2022, ensuring emissions are reduced across the globe and not exported from the UK. A global solution for a Global industry.

 

Answers to 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?

 

An immediate priority is to systematically progress airspace modernisation and ensure it is fully completed by 2033.  This would generate significant carbon savings as it progresses through more efficient flying and shorter journey times and which is a key component of our road-map. In the short term (at least the next 5 years) modernising UK airspace and enabling more efficient flight profiles offers the greatest opportunity to reduce UK aviation emissions. Current aircraft capabilities far exceed the operational opportunities due to airspace constraints.  

 

Airspace is critical national infrastructure that has not been fundamentally upgraded since the 1950s. Modernising and redesigning it will lead to less airborne holding, fewer miles flown per aircraft and less fuel burn[5]. Creating more efficient and streamlined airspace benefits airports and airlines but also the passengers and communities surrounding them, through reduced emissions. Government sponsorship of airspace modernisation is also now helping to focus attention clearly on the benefits this can deliver, which accounts for 20% of the SA commitment in the next decade and 5% overall by 2050. This accounts for 3.1 MtCO2 saving per annum from better air traffic management and operating procedures by 2050.

 

The pandemic’s impact on UK aviation, particularly the financial impact across the sector, puts the future of UK airspace modernisation at risk, if sufficient resources are not available to deliver against the modernisation programme. In March 2021 Government announced up to £5.5 million is to be made available to aid industry hit by the pandemic as it develops and evaluates new flight routes to modernise UK airspace. With the Government’s recent funding support, airspace modernisation can move forward and help to deliver better environmental performance ahead of those more radical innovations. Nonetheless, SA is concerned about the risks for delivering the UK airspace modernisation programme if this support is not sustained and built upon.

 

It will take at least 5 years to implement new SAF policies and have the initial plants operational, whilst next generation aircraft technologies are not expected until the mid-2030s.  It is critical that, through the Jet Zero Council, delivery of airspace modernisation is seen as a priority and any potential barriers or delays to progress are quickly identified and resolved.

 

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?

 

It is important to be clear that Sustainable Aviation Fuels should not be seen as ‘transitional’ fuels.

 

In the global aviation ‘Waypoint 2050’ carbon roadmap, the potential for electric and hydrogen aircraft compared to SAF and how this evolves over time was summarised.

 

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Source: Pg 48 Waypoint 2050 Global aviation roadmap

 

SA has compared this with other studies and whilst opinions vary, the diagram below assessed that the potential range for electric and hydrogen turbine technology in commercial aircraft, from 2040 onwards, is between 2,500km to 7,000km. That is significant and potentially game-changing for domestic, regional and short-haul flight.  However, the majority of the UK’s aviation carbon emissions are from long-haul flight.  There is currently no realistic, ‘in-sector’ technology pathway that delivers net zero flight for long haul other than through sustainable aviation fuels. 

 

Moreover, technology potential is not the same as actual operations.  It is unlikely that should a viable commercial medium range hydrogen powered aircraft become available in 2035, for example, that all global fleets would immediately transition into that model. SAFs will, therefore, need to play a critical role, both indefinitely for long haul flight but also for a long time yet as other parts of the sector transition to alternative aircraft.    

 

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Reaching commercial maturity

The first SAF facility in the UK has now secured planning permission: Subject to appropriate Government policies being delivered, Altalto Immingham, the UK’s first waste-SAF facility will be built in North East Lincolnshire. With the right Government support the UK can build a world leading sustainable aviation fuel (SAF) industry, with up to 14 UK-based SAF plants by 2035 bringing tens of thousands of jobs and £billions in GVA to former industrial regions of the country in seven clusters[6].

 

Through independently verified research the opportunity, with the right policy incentives and delivery our current aim is for at least 32% of UK Fuel supply to be provided by SAF by 2050. However, this assessment might change as the potential for SAFs made from new technologies creating Synthetic fuels from renewable electricity, hydrogen and captured recycled carbon, are assessed as part of our updated Road Map due next year.

 

Critically, SAF is today’s technology. The global aviation industry has certified 7 pathways up to 50% blend and is pursuing the capability for 100% Synthetic fuel flight. Over the last decade, SA has been fully engaged with the global industry work, and produced the first Sustainable Aviation Fuel Road-Map’s that set out the considerable opportunity for these low carbon fuels to decarbonise UK aviation, whilst also providing additional jobs and economic benefit to the UK. 

 

These jobs opportunities are set out below:

 

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The current level of SAF usage in the UK is however less than 1% of UK demand. The speed of development of the industry is too slow now and needs significant acceleration (we go into detail in answer to the question regarding support needed, below). Whilst the Government has begun to consult on positive incentives for UK SAF development and production, this is significantly less than the EU or US. With decisions by investors are being taken now and so we are urging the Government to set out a comprehensive policy framework for commercialising sustainable aviation fuels, alongside finance mechanisms that will be critical to delivering first-of-a-kind UK SAF plants.

 

We believe that the Jet Zero Council can play an important role as a catalyst in commercialising these technologies, but also, critically, must help to address the question of delivery and accountability, for policies that by their nature sit across a number of Government departments. The JZC should be able to consider low carbon technologies development as well as the industries performance in adopting these new and emerging solutions, whether ambition is being matched by the necessary policy action and investment, and also can evaluate any impact from policy developments outside the UK and how these might have affected the UK’s relative performance. SA believes this process is best managed through the Jet Zero Council.

 

 

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

 

SA believes that the two key emerging propulsion technologies - Hydrogen and Electric - will address short and some medium length air journeys with SAFs being used to replace fossil kerosene on most medium to all long haul flights.

 

Taking one example, in September 2020 Airbus revealed several zero-emission commercial aircraft concepts[7] which could enter service by 2035, including a turboprop design (up to 100 passengers) using a turboprop engine instead of a turbofan and also powered by hydrogen combustion in modified gas-turbine engines, which would be capable of traveling more than 1,000 nautical miles, making it a perfect option for short-haul trips.

 

It is therefore extremely important that HMG accelerates the development and implementation of nationwide hydrogen distribution systems plus airport electric and hydrogen charging and fuelling infrastructure. This is vital to the success of Zero emissions flight opportunities.

 

Beyond this there is an urgent need to commercialise and scale up carbon capture and removal technologies.  Aviation will become a major investor in these products for two reasons:

 

 

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?

 

Technology

New Aerospace technologies such as hybrid aircraft and longer term electric and hydrogen aircraft

offer exciting opportunities to decarbonise aviation. Ensuring the UK make the most of this

opportunity will involve sustaining the funding on innovation projects in this area. Currently this is

successfully enabled through the UK aerospace industry and Government Aerospace Technology

Institute (ATI), including their exciting ‘Fly Zero’ project.

 

Increased investment in the Aerospace Technology Institute is needed, to enable the technological innovations that will make net zero flight a reality. Hydrogen power has the potential to make huge strides towards decarbonising regional and medium-range commercial flights, but the UK needs a robust hydrogen policy and strategy that enables the production of green hydrogen in the volumes required by the industry. Significant progress is also being made in battery technology, which initially will be best applied to short range aircraft. However, maturing these technologies will allow industry to scale up to longer ranges.

 

The current endpoint of the ATI programme is March 2026, and budgetary commitments are already being made out to then. An extension of funding is vital if the ATI is to continue to fulfil its remit and support clean growth.

 

Regarding the UK hydrogen strategy, it is imperative that HMG consider both the scaling up of production of hydrogen alongside changes to the ground infrastructure for how this hydrogen will get to the airports and aircraft for aviation.  SA supports the work of the current Connected Places Catapult work but sees this as the start of the work not the end of it.

 

SAF

With the right Government support the UK can build a world leading sustainable aviation fuel (SAF) industry, with up to 14 UK-based SAF plants by 2035 bringing tens of thousands of jobs and £billions in GVA to former industrial regions of the country in seven clusters.

 

However, decisions by investors on which countries to invest in are being taken now and so we are urging the Government to set out a comprehensive policy framework for commercialising sustainable aviation fuels, alongside finance mechanisms such as loan guarantees or Green Bonds that will be critical to attractive the private investment needed for delivery of first-of-a-kind UK SAF plants. Specifically, any SAF mandate (currently being consulted on by the Department for Transport, alongside its overall Jet Zero strategy) needs to be implemented along with a price certainty policy by the end of 2022 at the latest, to ensure the UK realises the full potential from SAF by 2025.

 

This is because a mandate alone will not fix the ‘price gap’ that currently sees SAF cost around five times as much as ‘fossil’ jet fuel.  Proving price certainty, but also critically a competitive SAF markets for the end-user – i.e. airlines – will be critical to commercialising SAF and increasing uptake.    

 

Airspace modernisation

It is critical that, through the Jet Zero Council, delivery of airspace modernisation is seen as a priority and any potential barriers or delays to progress are quickly identified and resolved.

 

Enabling infrastructure

It will be critical to support development and delivery of additional infrastructure on the ground to enable zero emission flight.  This includes integrating national energy policies with Jet Zero policies to ensure there is sufficient electrical and hydrogen generation and supply to airports to support increased demand.

 

Carbon removal

In order to scale-up greenhouse gas removals (GGR), and particularly direct air carbon capture (DACS) solutions Sustainable Aviation encourage the UK government to:

●        Publish a coherent GGR strategy ahead of COP26: set specific science-based targets for GGR in addition to reductions, which will serve to increase investor confidence in first GGR plants

●        Accelerate GGR business models: GGR policy development needs to run in parallel rather than lag behind carbon capture and storage (CCS) policy development, so we call for a coherent GGR strategy setting out policy incentive proposals to commercialise the technology before the COP26 Conference in November

 

International agreement

Decarbonising aviation requires international cooperation and solutions, and UK leadership is vital. We need UK leadership in pursuit of a clear, long term CO2 target for global aviation, to be agreed at the 2022 ICAO Aviation General Assembly, and compatible with existing commitments.

 

 

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?

 

In short, by not doing so.  As highlighted in the Executive Summary to this response, UK aviation delivers considerable economic and societal benefits to the UK. The appropriate pathway to enable UK aviation to continue and to grow, with demand dampening measures applied only if the sector is unable to decarbonise within a carbon ‘ceiling’ determined by the requirements of the science and by the UK’s overall net zero carbon trajectory. 

 

Any steps taken in the UK must recognise that aviation is by its nature a global industry, with emissions from global aviation 17 times those of the UK. This is not an excuse for inaction, but rather is evidence of why the best course to deliver our local and global decarbonisation goals is to invest in the solutions that will enable delivery as well as international cooperation, rather than undermine the UK’s competitiveness without impacting the wider global picture and aviation emission levels.   

 

 

UK aviation has assessed that UK aviation can grow by around 60-65% in 2050 compared to 2019 whilst still meeting net zero 2050 and with emissions pathways similar to those assumed by Government, and by the Committee on Climate Change (CCC).

 

What matters is that UK aviation is able to decarbonise in line with what is required to achieve the UK’s net zero targets. The two charts below show how SA’s gross and net emission pathways compare to the DfT high ambition gross scenario and the UK Committee on Climate Change’s (CCC) sixth carbon budget, Balanced Pathway scenario;

 

 

And then the DfT lower and higher net emission trajectories as well as the CCC net emission pathway using greenhouse gas removals.

 

 

The CCC’s recent specific aviation policy recommendations now show much closer agreement with Sustainable Aviation’s own analysis, in particular by recognising a much bigger role for SAF in reducing emissions by 2050. The new SA forecast for both gross emissions (actual aircraft emissions) and net emissions (aviation emissions after greenhouse gas removal and carbon trading schemes such as UK ETS, EU ETS and CORSIA are taken into account) are similar or lower than that assumed by the CCC in their 6th carbon budget analysis to around 2030.

 

SA is encouraging the Government to stay focussed on enabling technology solutions and implementing international policies that reduce aviation emissions as a priority and only if these solutions do not result in UK aviation meeting the net zero emissions trajectory should alternative interventions be considered. Mitigation action – i.e., demand management through unilateral UK taxes or levies - should only be required if the industry performance goes above the upper trajectory line.

 

For example, taxation should be seen as a measure of last resort to address carbon emissions. This is because aviation takes place in a global marketplace, so any UK specific tax measures risk putting UK aviation companies at a disadvantage to non-UK companies.  Since its inception, SA has cautioned against the role of unilateral aviation taxes as an appropriate or cost-effective means to deliver or drive aviation decarbonisation, compared to alternatives that seek to deliver genuine in-sector reductions through the delivery of innovative new technologies, working alongside carbon pricing and effective carbon market-based measures (MBMs) like the new UK ETS and global CORSIA scheme.

 

Ultimately, investment in new lower emission technologies, use of sustainable fuels and airspace modernisation will have a larger impact at reducing aviation emissions globally, not just in the UK. Further taxation for flights leaving the UK risks problems such as carbon leakage, where people choose to buy cheaper flights outside the UK, that avoid UK taxes, but in doing so support flights over longer distances than direct flights from the UK, thus creating more carbon.

SA continues to encourage the Government to work with the industry, through the Jet Zero Council to support a green recovery of the UK and aviation that nurtures a leadership position and accelerates progress at a global level to decarbonise aviation.

 

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?

 

Advice from the UK Committee on Climate Change and other reports recognises aviation is a hard to decarbonise sector and therefore should be eligible to address any residual emissions once all efforts have been made to minimise emissions, through access to carbon removal solutions. There will be a role to play for high-quality offsetting in aviation if we are to reach net zero and we agree with them on that. Specifically, they say 60-110 Mt of removals are needed for the UK’s emissions per year by 2050.

 

Decarbonising aviation requires international cooperation and solutions, and UK leadership is vital. We need UK leadership in pursuit of a clear, long term CO2 target for global aviation, to be agreed at the 2022 ICAO Aviation General Assembly, and compatible with existing commitments, for once CORSIA ends in 2035.

 

Through CORSIA UK airlines will pay billions of dollars to fund carbon reduction through high-quality, independently verified carbon offsets, whilst also being incentivised to reduce emissions ‘at source’ through the effective functioning of the carbon market.

 

The UK should be looking at COP26 as an opportunity to drive support for global action and investment in aviation decarbonisation, through both supporting technological solutions, but also through CORSIA.

 

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?

 

As highlighted above, we need UK leadership in pursuit of a clear, long term CO2 target for global aviation, to be agreed at the 2022 ICAO Aviation General Assembly, and compatible with existing commitments, for once CORSIA ends in 2035. Such an agreement has the potential to be very effective at helping drive down emissions from aviation, in concert with other schemes such as the EU and UK ETS – so long as these schemes are coordinated and avoid undue complexity.

 

SA, along with industry, governments and climate science, have consistently advocated for carbon pricing and effective carbon market-based measures (MBMs) as an essential element in reducing emissions in the aviation sector, rather than unilateral ‘eco’ taxes targeted only at air transport and introduced in individual countries. This means mandatory regulation that harnesses the power of markets to seek emission reductions where they can be made most costeffectively and applied equitably in air transport markets to avoid competitive distortion and carbon leakage.

 

To achieve the first requirement - environmentally and cost-effective emissions reduction – policies measure must allow access to a range of abatement options in multiple sectors and countries. This market-based approach means that the cost of emissions reductions is established by projects that are most able to generate them. This means that airlines and their customers pay no more than necessary for meaningfully achieving carbon targets. Over time, as global structures to support carbon pricing mature, the cost of carbon can be expected to increase.

 

The second requirement – equity – is achieved by carefully designing the scope and rules of the policy measure with the objective that all airlines face equal treatment. Market distortion will occur where the cost per tonne of CO2 of a policy measure is different between different airlines, leading to carbon leakage and potential increase in net emissions. In air transport markets this can affect simple point-to-point markets as well as indirect transfer market