West london Friends of the Earth ZAS0045
Written evidence from West London Friends of the Earth
1. Introduction
West London Friends of the Earth (WLFOE) is a network of borough-based Friends of the Earth groups. It exists to address issues which go well beyond borough boundaries but which have a particular resonance in West London. Heathrow airport is a case in point.
This response only addresses aviation – we have no comments on shipping.
2. The role of technology
A profound and prescient comment was made many years ago “There are no technological fixes to our environmental problems – only social, economic and political ones” (reference not available). Nowhere is this truer than the issue of GHG emissions from aircraft. This being so, we are concerned that there is too much emphasis on technology in the questions asked.
There are various ‘techno-fixes’ promoted by the aviation industry and its supporters, including more efficient planes, biofuels, artificial fuels, hydrogen and electric planes. There is a large amount of evidence, from impartial sources, that none of or even all of them together will get us anywhere near Zero Carbon. Comments and references are provided in some other responses and we would, in any case, expect the secretariat to provide members of EAC with such background information. This being so, we do not see the need to discuss the options in detail. However, a very brief summary of the issues may be helpful insofar as it highlights the inadequacy of techo-fixes.
3. Problems with techno-fixes
More efficient planes. The best estimates suggest that improvements in aircraft design will lead to an improvement in efficiency of just 1% pa or a little above. This is far less than the projected growth rate of aviation.
Biofuels. There is no spare land for growing biofuels. All the world’s land is already needed for food or for habitat protection and ecosystem services. In any case, biofuels are not carbon neutral as long as fossil fuels are used in the processing and transport of the biofuels.
Artificial fuels. These can use CO2 from the atmosphere as a source and might therefore seem to be carbon neutral. But the process of synthesising fuel requires large inputs of energy. As long as fossil fuels are used in the manufacture and transporting of artificial fuels, artificial fuels will not be carbon neutral.
Hydrogen. This has been described, with some justification, as “the world’s worst fuel”. It is the lightest of all gases, which means it needs large or strong high-pressure tanks to store it. It is also very mobile, readily escaping from joints. Hydrogen only liquefies at an unpracticably low temperate and rapidly evaporates. Free hydrogen does not occur on earth and has to be made with high input of energy. As long as fossil fuels are used in the manufacture and transporting of artificial fuels, hydrogen will not be carbon neutral. It might be observed that burning hydrogen creates only water and is thus preferable to fuel containing carbon. But this is illusory in the case of aircraft. Water emitted at altitude is a greenhouse gas, by virtue of its effect in forming contrails and cirrus clouds.
Electric planes. These require heavy batteries. Batteries are nowhere near as ‘energy dense’ as kerosine so electric planes are not viable for any by but the shortest flights. Batteries need to be charged of course and as long as fossil fuels are used in producing electricity, electric planes will not be carbon neutral.
If will be observed that most of these measures require electricity to work and that the electricity needs to be renewable. But it is not enough for a particular supply to be renewable. Until the entire grid is de-carbonised and there is generating capacity to spare, any extra demand for electricity for aviation will simply use up or divert existing renewable energy and increase the need for generation with fossil fuel.
4. Offsets
Offsets are frequently touted as part of the solution to aircraft emissions. They are not a solution they are ‘greenwash’. For an offset to be effective the emissions saved in the sector that aviation is being offset against must be additional to what would have happened anyway. Studies show that most offset schemes do not meet this additionality criterion. Just as serious, all the non-aviation sectors need to get to zero carbon in their own right. Therefore, except in the short term, there will be nothing to offset against.
5. Carbon capture and storage
Given the immense difficulties in achieving zero emissions from aviation, there is one possible solution. Namely carbon capture and storage (CCS). In this process, the residual CO2 emitted by aircraft (after all reduction measures have been applied) is taken back out of the atmosphere and buried long term in the earth’s crust. But this requires energy, so that energy has to be zero carbon. Unfortunately, there is no evidence that CCS can and will be available on the scale needed in the timescale needed. There is a grave danger of CCS sometime in the future being used as an excuse not to reduce emissions now.
6. Answers to questions posed by EAC
What contribution can operational efficiencies make to reduce emissions from aircraft / shipping vessels and over what timescale could these have an effect on emissions?
The best estimates suggest that improvements in aircraft design will lead to an improvement in efficiency and a corresponding reduction in emissions per passenger km (or per tonne) of 1% pa or a little above. As the projected growth is up to 5% worldwide (less in the UK as it is a mature market) improvements will nowhere near offset the growth, let alone take us towards zero carbon.
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?
There are virtually no genuinely zero carbon fuels. (Hydrogen could be in a literal sense regarded as zero carbon.) All biofuels and chemically derived fuels require energy to be produced and transported and for the foreseeable future much of this energy will be derived from fossil fuels.
What new technologies are there to reduce emissions from aircraft / shipping vessels and how close to commercialisation are they?
We leave it to the specialists to say where the new technologies are at. But how close they are to commercialisation is not just a technological issue. It depends greatly on the economic (taxes, subsidies, etc) and political (regulation, etc) environment.
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?
We do not have comments on exactly how UK industry should be supported. But we note that in a market economy it is not the role of government to ‘bale out’ industry. It is the job of the industries concerned to make their products safe (in climate terms) and conform to regulations. That said, we would not be opposed to government support as long as it was paid for out charges or taxes (eg a carbon tax).
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?
The wrong question is being asked here. The key requirement is to reduce emissions – that will benefit rich and poor alike.
A key reason for the volume of aviation and projected increase is that it is so cheap. Flying is very ‘price elastic’, that is an increase of price reduces demand, and that is because it is a luxury. A key policy should therefore be to increase the price.
Aviation is massively undertaxed compared with the rest of the economy and this should be rectified forthwith. There is no tax on fuel, an exemption worth over £10 billion pa to the industry and its customers. There are problems with international treaties but if these cannot be overcome, there is a range of proxies that that can be used, such as airport taxes or increasing APD. There is no VAT on tickets and no carbon tax.
The question of equity has to be secondary. The idea of a Frequent Flyer Levy (FFL) has gained traction in recent years, but great caution is needed. It would be quite complex and expensive to administer and this must not be used as justification for not taxing aviation. Fuel taxes and APD are, in contrast, relatively simple and cheap to administer.
FFL was proposed as a mean to avoid the alleged problem that aviation taxes would prevent poorer people flying – an equity issue. But this equity issue is largely bogus, invented by the aviation industry lobbyists to argue against taxing any aviation. The fact of the matter is that poor people don’t fly. They do not jet down to their second home in Spain 6 times a year, go to stag do’s in Prague or fly to a beach in Goa. People struggling to pay their rent or even put food on the table have more pressing concerns than jetting abroad. For this reason, higher aviation taxes would be ‘progressive’ - taxing the affluent rather than the poor. If we – and members of EAC – really care about poor people we should argue to help them directly, perhaps with revenues from aviation taxes. Not use poor people as justification for a tax dodge (tax free fuel, etc) for the affluent.
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?
We do not have comments on this. We would simply say that the key requirement is the political will to act.
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?
CORSIA will not, in general terms, be effective. If has two massive failings. Firstly, it does not aim to even reduce emissions let alone move towards net zero. Secondly, it relies on offsets which are now widely recognised as not being a credible method removing emissions. There is a serious danger that CORSIA will be used as ‘greenwash’, diverting attention from more effective and drastic action that is needed.
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?
We do not have comments on this.
7. Comment on stance of EAC
We are very concerned that the comments of the EAC chair which suggest a pre-judgment of attitude that is not favourable to serious action on climate change.
“We must find ways to support the aviation and shipping sectors”. We (WLFOE) do not consider that aviation is should be singled out for the support. The great majority of air travel is for leisure and it is a luxury – a luxury among many others that are not a priority for support. The other uses – cargo and business trips - are simply a service to support other sectors of the economy (in the same way that lorries and trains support movement of cargo and business people respectively). There is no justification for encouraging and supporting aviation for its own sake.
“.. emissions could double by 2050. There are bold ambitions – unveiled by Government only last week – for new technology to lower our share of international aviation’s carbon emissions to net zero by 2050.” This displays a completely unjustified assumption that technology can get us to zero carbon. As noted in **. social, economic and political action is all-important.
These are of course just two quotes from a short statement. But they give a worrying indication that EAC may put pandering to the aviation lobby and avoiding difficult political decisions ahead of the need to take drastic action on climate.
If this EAC mindset is confirmed, WLFOE may reluctantly conclude that engagement with politicians via traditional methods is a waste of time and that its members should seek alternative approaches.
Nic Ferriday
September 2021