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Written evidence from ZeroAvia

Introduction

ZeroAvia is pleased to respond to the Environmental Audit Committee’s Inquiry into Net Zero Aviation and Shipping. We would be delighted to welcome the Committee to our R&D base at Cotswold Airport in Kemble to show our technology and discuss our near and long term ambitions.

We are a UK-business that is pioneering zero-emission hydrogen-electric aviation. In 2020, at Cranfield Airport we successfully conducted the world's first ever hydrogen fuel-cell powered electric flight, in a commercial grade aircraft under the Hyfler I project, with support from the Government through the Aerospace Technology Institute (ATI) programme. We are currently working to scale up the technology through the HyFlyer II programme (also supported through the ATI) which will see the development of a certifiable hydrogen-electric powertrain that can power airframes carrying up to 19 passengers. Commercial hydrogen-electric flights are planned to begin from 2024 onwards.

ZeroAvia is aiming to scale-up its technology quickly to offer zero emission powertains to increasingly larger aircraft with longer potential range - targeting 50 - 80 seat aircraft with 1,000 nautical mile (nm) range by 2026, right through to 200+ seats with a 5,000nm range by 2040. Passengers could fly without any greenhouse gas emissions from London to Istanbul before the end of the decade, and from London to Los Angeles within 20 years.

In addition to allowing zero emission flights, hydrogen-electric aircraft will stimulate the introduction of hydrogen powered buses, taxis, trains and other vehicles within and around airports. This will increase demand and production of locally produced, zero carbon green hydrogen fuel.

We are, however, at a pivotal point in UK-led hydrogen-electric aviation. Whilst the UK is currently world-leading in this technology, other nations are catching-up. Whether or not the UK seizes it’s hydrogen-electric aviation opportunity will, to a significant degree, depend upon Government policy.

Overall, our key points to the Committee are that hydrogen-electric technology offers four major decarbonisation and economic opportunities for the UK:

1. Zero emission commercial flights: Sustainable aviation fuels (SAFs) have a role to play in transitional decarbonisation, but they are expensive, difficult to scale and still carry harmful emissions including nitrous oxide and soot. As well as offering complete elimination of carbon emissions in flight, hydrogen-electric aviation emits only water. Hydrogen-electric aviation also reduces noise and vibration and will allow more affordable access to a crucial method of transport for both passenger and logistic carriers, thanks to significant predicted reductions in operating costs.

2. World-leading, UK-based innovation: ZeroAvia employs c50 people in the UK in highly skilled R&D jobs and is rapidly growing. British Airways is an investor in ZeroAvia, British airline operators such as Loganair will be among the first to commercially fly hydrogen-electric planes, and UK regional airports are keen to implement hydrogen technology. ZeroAvia is working with leading UK suppliers as part of the HyFlyer II programme.

3. Supporting 2030 decarbonisation goals: The Government has an ambition to produce 1GW of hydrogen by 2025. The demand for green hydrogen for aviation will help to unlock private investment in production facilities during this Parliament, accelerating from 2025-2030 as our technology further develops.

4. Creating hydrogen hubs: Unlike SAFs, hydrogen-electric aviation technology and supporting infrastructure can be used to unlock the wider introduction of hydrogen technology such as support vehicles, connecting trains, buses, taxis and nearby industrial uses.

We agree with the Secretary of State for Business, Energy and Industrial Strategy when he said in the foreword to the Hydrogen Strategy that: “our ambition for hydrogen goes beyond decarbonisation.[1]”  Hydrogen-electric aviation is also a significant opportunity to manufacture in the UK planes that will be used across the world, supporting jobs across the supply chain and maximising our innovation and expertise.

In order to capitalise on this decarbonisation and economic opportunity, we propose five policy steps that we urge the Environmental Audit Committee to consider:

1. Ensure that investment in zero emission technology for aviation is prioritised, including through extension and expansion of the ATI’s funding and mandate.
2. Collaborate with regulators and industry to drive adoption, investment and innovation.
3. Support the public to fly zero emission through incentives such as Air Passenger Duty as in Norway.[2]
4. Use hydrogen-electric aviation to stimulate hydrogen hubs around airports as in France where companies including Airbus, Groupe ADP, and Air Liquide are working to deliver hydrogen at airports and transform them into hydrogen hubs.[3]
5. Provide a supportive regulatory framework for innovation by expanding the specific and funded support available at the Civil Aviation Authority to ensure that new zero emissions aviation programmes can be fast tracked while maintaining the outstanding safety and regulatory standards the aerospace sector depends on.

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

ZeroAvia is supportive of initiatives to improve the overall efficiency of the aviation sector’s operations, although some initiatives relating to the efficiency of aircraft propulsion will likely be negated with the adoption of zero emission aviation, particularly hydrogen-electric.

As well as the removal of in-flight emissions, investment and support for hydrogen-electric propulsion technologies can lead to reduction in carbon emissions from ground operations, and wider transport around airports. The Transport Decarbonisation Plan highlighted the importance of hydrogen hubs and airports are ideally suited to this. In addition to aircraft, hydrogen is well-suited to powering other types of heavy vehicles and machinery commonly in use at airports in logistical operations. With large numbers of passengers connecting to other modes of transport such as buses and trains, and high volumes of road freight feeding airport operations, the potential to use hydrogen fuel cell technology to decarbonise these vehicles is aided by the adoption of hydrogen-electric propulsion and refuelling operations at airports.

ZeroAvia and partners have already developed the Hydrogen Airport Refueling Ecosystem (HARE) – inclusive of an on-site electrolyser. This system was used to power the breakthrough flight testing programme of ZeroAvia’s HyFlyer I and is in continued use as part of HyFlyer II. It demonstrates the potential for airport production of green hydrogen through electrolysis - this can have a systemic impact on reducing the emissions associated with ground operations and with the wider airport ecosystem.

With this in mind, any regulations that make it favourable for operators to adopt leading zero emission technologies should be encouraged.

Hydrogen-electric technologies will offer improved operating costs, and combined with further efficiency improvements, this can significantly improve the competitiveness of zero emission operations, helping operators and consumers to make more sustainable decisions.

How close are zero carbon fuels to commercialisation for aviation?

The UK has a once-in-a-lifetime opportunity to be a global leader in zero-emission aviation technology that will be essential if we are to meet Net Zero targets and drive economic growth. ZeroAvia successfully conducted the world's first ever hydrogen fuel-cell powered electric flight in a commercial grade aircraft last year and commercial hydrogen-electric flights of 19-seat aircraft are planned to begin from 2024 onwards.

Based on ZeroAvia’s technology roadmap, truly zero emission hydrogen-electric aircraft will be capable of powering nearly all domestic take-offs before 2040. From 2024 onwards, ZeroAvia will deliver HyFlyer II, a zero emission hydrogen-electric powertrain for aircraft of up to 19-seats. This programme will commence its first flights in 2021, and will be fully certified for market entry with early-adopting operators, including UK domestic airlines. From 2026, ZeroAvia will deliver certified hydrogen-electric powertrains for operators powering regional aircraft of over 50 seats, capable of flying 1,500NM.

This means hydrogen-electric aviation can contribute significantly towards 2030 decarbonisation goals whilst minimising behaviour change.

By scaling quickly from today, regional hydrogen-electric planes will be flying 100-200 passengers up to 2,000nm by 2030. With the right policy framework, the UK could have a network of zero-emission capable airports, able to support both hydrogen ground vehicles and taxis, trains and buses that serve the airport, as well as UK-made hydrogen-electric planes for our domestic aviation industry.

However, we must act fast to seize this opportunity, or we risk losing out to other nations. France, Norway, and the Netherlands are already implementing policies to nurture hydrogen-electric aviation. We urge Government, local leaders and industry to seize this opportunity, and provide the necessary funding and policy support to accelerate progress now. We therefore propose four policy steps that the Environmental Audit Committee should consider to maximise the UK’s hydrogen-electric aviation opportunity:

1. Ensure that investment in zero emission technology for aviation is prioritised, including through extension and expansion of the ATI’s funding and mandate.
2. Collaborate with regulators and industry to drive adoption, investment and innovation.
3. Support the public to fly zero emission through incentives such as Air Passenger Duty as in Norway.[4]
4. Use hydrogen-electric aviation to stimulate hydrogen hubs around airports as in France where companies including Airbus, Groupe ADP, and Air Liquide are working to deliver hydrogen at airports and transform them into hydrogen hubs.[5]

What role should transitional fuels such as alternative hydrocarbon fuels play?

While SAFs have a role to play in reducing aviation’s carbon emissions, they are far from a holistic solution, nor do they fully address the sector’s climate impacts. SAFs are projected to be expensive and limited in availability, and while they would reduce carbon emissions they will still produce other emissions that contribute to climate impacts. The Government should therefore prioritise truly zero emission solutions for domestic aviation, as the technology pathways will mean that those solutions will be capable of addressing the domestic aviation sector’s needs comfortably ahead of 2040.

ZeroAvia also believes it is important to understand, model and track the wider climate and air quality impacts that SAFs would still generate, such as NOx and particulates. Additionally, some forms of SAFs may have harmful impacts on biodiversity that run contrary to the Government’s policies for agricultural and countryside reform. While preferable to kerosene based fuels, SAFs are not the optimum long-term solution.

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?

ZeroAvia is confident that with the right support and incentives, and the availability of the underpinning hydrogen fuelling infrastructure, operators will readily begin decarbonising their domestic fleets well ahead of the 2040 domestic target as defined in the Transport Decarbonisation Plan. Once this area of the sector has been decarbonised and as the technology matures, international routes should follow suit.

Through investment, research, development and manufacturing, the UK has the potential to be an early mover in a market valued in the billions that will lead to global exports as others follow suit. An ambitious mandate for domestic aviation is a rare win-win. It is a chance to deliver crucial environmental objectives while seizing an advanced industrial opportunity to support future prosperity.

ZeroAvia is urging the Government to:

1.       Ensure necessary investment in R&D: maintain and expand the position of leadership that the UK has established around zero emission flight technology.

2.       Identify and back the right solutions: analyse the roadmap for zero emission technology to ensure priority of adoption, investigate the full climate change impact of potential solutions (including non-CO2 impacts), and analyse the viability and cost implications of all decarbonisation solutions.

3.       Provide a supportive regulatory framework for innovation:  we recommend that the Government expands the specific and funded support available at the Civil Aviation Authority to ensure that new zero emissions aviation programmes can be fast tracked while maintaining the outstanding safety and regulatory standards the aerospace sector depends on. The relatively low costs of action here significantly outweigh the societal and economic impacts of slow progress in achieving certification for new technologies.

4.       Support the development of airport infrastructure for zero emission technology: the recent Connected Places Catapult Zero Emission Flight Infrastructure initiative, supported by the Department for Transport is a positive start, but will need to be built upon and expanded in order to match the development and capabilities of flight technology.

5.       Create the right incentives to switch: as technologies are commercialised, the Government should consider stronger mandates that incentivise operators to upgrade their fleets as swiftly as possible. For example, this may be by reducing or removing Air Passenger Duty on zero emission flights, or by supporting operators with tax relief to make fleet improvements. Other measures such as the short-haul flight ban (with exemption for zero emission aircraft) implemented in France could also be reviewed.

6.       Encourage adoption of zero emission technology on Public Service Obligation routes: as well as setting the example for wider industry adoption, this will have the benefit of reducing the operational costs of these routes, potentially pushing them towards commercial viability.

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)?

ZeroAvia appreciates the Committee’s view that action should be taken to reduce aircraft passenger numbers, but we aspire to allow the aviation industry to thrive in a zero-emission future, rather than managing a controlled decline.

A recent report by the Tony Blair Institute, Planes, Homes and Automobiles: The Role of Behaviour Change in Delivering Net Zero, set out how “the most politically deliverable pathway to Net Zero is one that focuses on a limited number of behaviour changes, minimises the need for massive lifestyle changes such as an end to flying...and that maximises the delivery of wider benefits.[6]”

Reducing passenger numbers does not take account of both the enormous economic, societal and cultural benefits of air travel and the fact that near-term solutions to allow green aviation are at hand.  Aviation connects people, broadens horizons and allows cultural exchange. It also supports economic growth - both globally by facilitating travel and commerce between nations, and regionally by connecting communities that can be otherwise inefficient to travel between. Domestic aviation, by enabling people to easily meet, work together and do business, should be viewed as a critical tool in the Government’s plans for levelling up the UK’s regions and connecting the Union. This can be done while reducing the environmental impact of aviation.

We believe that the UK Government should work closely with industry to seize the opportunity hydrogen-electric aviation provides. This would allow the public to keep flying with minimal behaviour change, while also creating high-skilled, green UK jobs and reducing carbon emissions. We are pleased that it is recognised in the Hydrogen Strategy that: “the Government will work with industry, academia and other stakeholders to...assess what actions government, industry and the research and innovation community could take to seize the supply chain opportunities presented by the early development of a low carbon hydrogen economy, and for UK businesses to position themselves at the forefront of the hydrogen economy.[7]”

The UK aviation industry contributes £52bn to the UK economy, supports 960,000 jobs and provides £8.7bn in taxation to HM Treasury. It is estimated that an additional £6.3bn of government revenue is raised in the aviation sector’s supply chain and the UK’s aviation manufacturing sector makes a £9.0bn direct, £6.7bn indirect, and £4.1bn induced contribution to UK GDP.[8]  UK hydrogen-electric aviation is a critical opportunity for the UK aviation sector, and one that can, as the BEIS Secretary has said: “support industry to develop sustainable, home-grown supply chains, create high quality jobs, and capitalise on British innovation and expertise.[9]”

September 2021