Stansted Airport Watch                            ZAS0047

Written evidence from Stansted Airport Watch

1.        

2.       Introduction

2.1   Stansted Airport Watch ('SAW') welcomes the opportunity to make this submission to the Environmental Audit Committee ('EAC') in response to the EAC's call for evidence on 'Net Zero Aviation and Shipping'. Our comments are confined to the aviation sector.

2.2   The UK is the world's third largest air travel market and accounts for 8.6% of all international flights[1] but less than 1.0% of the world's population. More than two-thirds of the UK air travel market is by UK residents making overseas visits, of which just 9.5% were business related.[2] In 2019, the UK posted a £34 billion trade deficit on international air travel. 

2.3   Notwithstanding the current scale and underlying nature of the UK air travel market, the Department for Transport ('DfT') continues to support unconstrained growth. This policy is increasingly difficult to justify, above all, because it is wholly inconsistent with the UK's commitment to tackle climate change.

2.4   Section 1 of the Climate Change Act ('CCA') requires the government to achieve very substantial reductions in greenhouse gas ('GHG') emissions. The original requirement was to achieve an 80% reduction by 2050[3], compared to 1990 levels. In June 2019, the CCA was amended to require 'Net Zero' emissions by 2050.

2.5   In December 2020, the Committee on Climate Change ('CCC') provided its statutory advice to the government ahead of the Sixth Carbon Budget ('6CB') and this included the following key recommendations for the aviation sector:

  (i)              International aviation (and shipping) should be included in the 6CB;

(ii)              The DfT's planning assumption for aviation emissions in 2050 should be reduced from 37.5 million tonnes of carbon dioxide ('MtCO2') to 23MtCO2;  and

(iii)              There should no net expansion of UK airport capacity until the aviation industry is able to demonstrate that it is on track to undershoot 23MtCO2.

2.6   The DfT has accepted the first of the above recommendations but rejected the other two, i.e. the reduction in the planning assumption for aviation to 23MtCO2[4] and a moratorium on airport expansion until the industry is on track to reduce its emissions to 23MtCO2 by 2050.

2.7   Accordingly, the DfT continues to support what amounts to a 'business as usual' approach by encouraging expansion at every UK airport, through the Airports National Policy Statement ('ANPS') in relation to Heathrow, and the Making Best Use ('MBU') policy[5] in relation to every other UK airport.  Both of these policies were published in June 2018 and therefore pre-date the 'Net Zero' amendment to the CCA and the CCC's advice on the 6CB.

2.8   Alongside the MBU policy, the DfT published analysis aimed at demonstrating that the 37.5MtCO2 planning assumption could still be met even with a third Heathrow runway and the MBU policy (see Annex A).  To date however the DfT has not updated this analysis in the light of the 2019 Net Zero amendment to the CCA.

2.9   Instead, the DfT has published a 'Jet Zero' Consultation[6] accompanied by a so-called 'Evidence and Analysis' paper both of which appear to be largely based on wishful thinking rather than reasonable expectation.  Nevertheless, the DfT concludes:

"Our trajectories also indicate that aviation net zero can be met by 2050 with future capacity assumptions consistent with Making Best Use policy and the Airports National Policy Statement."[7]

2.10     For the reasons set out in the following sections of this paper, we are not persuaded that the DfT actually does have a coherent strategy to deliver aviation net zero ('Jet Zero') by 2050.

3.       Overview of the DfT Jet Zero Strategy

3.1   The DfT fails to provide credible evidence or analysis to support its claim that it can achieve Jet Zero by 2050, and its claim is subject to numerous caveats and conditions, for example:

“We recognise that net zero 2050 must be achieved and we must ensure that any growth in aviation is compatible with our emissions reduction commitments. The approach we intend to set out in our Strategy … relies on the rapid scale-up and deployment of technologies that are currently at a relatively early stage of development and requires collaboration and commitment across all parts of the sector if it is to succeed.” [8]

"… many of the technologies needed to achieve net zero aviation are in the early stages of development and there is significant uncertainty regarding the expected cost, availability and uptake of these technologies over the coming decades.”[9]

"…  the four scenarios we have modelled … show that significant in-sector abatement could be possible if we make substantial progress with new technologies. However, making the required technological progress will be very challenging and there are many barriers that will need to be overcome." [10]

[Emphasis added]

3.2   In other words, the objective must be achieved but we are relying on untried and untested technologies, which in some cases are still to be invented.  Put shortly, it is a plan of hoping for the best whilst continuing with business as usual.

3.3   The words “uncertain”, “uncertainty” and “uncertainties” together occur no fewer than 27 times in the Jet Zero Consultation (including the Evidence and Analysis paper). Such caveats sit uncomfortably with a strategy which "must be achieved" and with the imperative of tackling the threat of climate change. There needs to be greater clarity and certainty. 

3.4   Under the DfT's preferred scenario ("High Ambition”) aviation CO2 emissions continue to increase until 2028 and then only reduce back to pre-pandemic levels by about 2033.  The comparison between the DfT's approach and the CCC’s recommended approach for future aviation emissions, is as follows:                                            

                                            Reduction in UK aviation CO2 v pre-pandemic levels

3.5   It can be seen above that the DfT's approach is heavily backloaded, compared to the CCC's recommended approach of requiring early reductions. Backloading is a risky strategy and it results in higher cumulative emissions to 2050. It is also far more speculative, being dependent upon technologies not yet developed and, in some cases, not yet invented. Furthermore, these new technologies must be fully developed, up-scaled and deployed as commercially viable solutions in relatively short timescales which adds a further risk factor.

4.       Fuel Efficiency Improvement

4.1   The DfT itself acknowledges that its assumption of 2.0% p.a. fuel efficiency improvement over the period 2017-2050 is both optimistic and speculative, viz: 

"Achieving such a high rate of fuel efficiency improvement will also be challenging, and may not be met if airlines cannot afford to invest in modernising their fleets at sufficient speed, or if the aerospace sector cannot afford to invest in creating the necessary aircraft advancements (made even more likely by the huge financial impact of Covid-19 on the aviation industry)."  and

"Based on optimistic scenario from ATA research and in line with ICAO aspirational goal".[13]

  [Emphasis added]

4.2   The DfT claims that the ATA research figures translate "… to a fuel efficiency improvement of between 1.5% and 2.0% per annum (for the 'Likely' and 'Optimistic' scenarios referenced in the research)"[14] but even the 'Likely' figure of 1.5% is optimistic when considered against other research evidence and the advice from the CCC.

4.3   A report by the International Council on Clean Transportation ('ICCT')[15], referred to by the DfT, found that aircraft fuel efficiency improved at an average rate of 1.5% p.a. between 1960 and 2008 However, the DfT does not refer to a more recent report by the ICCT which found that aircraft fuel efficiency improved at the lower rate of 1.3% p.a. between 1968 and 2014, indicating a significant slowdown in efficiency improvement between 2008 and 2014.[16]

4.4   By comparison, the CCC, for its 'Balanced Net Zero Pathway' scenario, assumed an annual fuel efficiency improvement of 1.4%[17] and Stansted Airport, in its recent planning application, provided three scenarios for annual fuel efficiency improvement: 'Pessimistic' 0.9%; 'Central Case' 1.25%; and 'Best Practice' 1.6%.[18] All of the foregoing indicates that the DfT has taken a highly optimistic view in projecting 2% annual fuel efficiency improvement.

5.       Sustainable Aviation Fuels ('SAFs')

5.1   The DfT assumes an uptake of 30% SAFs by 2050 which it states is "in line with the CCC's Balanced Net Zero Pathway". The CCC figure for 2050 is actually 25%[19] and this accounts for the difference in the projected saving in 2050. The DfT's assumption is therefore optimistic and it is heavily backloaded. This is a high-risk approach because it allows little time to adopt and implement an alternative strategy if the preferred strategy fails to deliver.

5.2   Even based on optimistic assumptions for fuel efficiency and SAFs, the DfT projects that aviation emissions in 2035 will be little different from pre-pandemic levels, thus making no contribution to the government commitment to reduce emissions by 78% by 2035.

5.3   The DfT acknowledges that there are numerous concerns about SAF production and cost:

"Current SAF use in UK aviation is negligible and there is significant uncertainty around the availability and cost of SAF in the future."    and

"The costs of SAF are high and uncertain, ranging from two-three times the price of the fossil alternative, and potentially up to eight times more for certain technology pathways".[20]

[Emphasis added]

5.4   The DfT cites a projection from the 'Clean Skies for Tomorrow' report that feedstocks could supply almost 500Mt of SAF by 2030[21] but the report notes that the major problem is production capacity. SAF production in 2019 was less than 0.1% of commercial jet fuel and, if all the projects that have been publicly announced were to be built, annual capacity would reach just over 1% of expected global demand in 2030. The report goes on to say:

"Scaling up each production pathway presents a range of challenges. For example, some feedstocks may be difficult to collect in sufficient quantities and some technologies need additional maturation through research and development to become practical. Demand for SAF would need to rise dramatically in the next few years even though it is likely to remain significantly more expensive than fossil fuel for decades." [22]

5.5   The DfT needs to provide rapid and substantial encouragement, with clear policy support and incentives, for SAF production and use to reach 30% by 2050. The policy proposals contained in the Jet Zero Consultation are vague and lack urgency. A 'wait and see' approach is unsatisfactory.

5.6   The DfT proposes to review SAF by 2030 "once the supportive policy framework is in place, and SAF production is being scaled up".[23]  In our view, this is far too casual an approach.  Far more urgency is required and there needs to be a clear plan, with milestones, to reach the DfT's ambitious assumption of 30% SAFs by 2050.

6.       Battery and Hydrogen Technology

6.1   The problems with battery and hydrogen-powered flight are well documented.  With batteries weighing more than 40 times the equivalent kerosene it is unlikely that they will be suitable for anything other than small aircraft on short flights other than in the very long term.  Hydrogen has a volume requirement of four times greater than conventional fuel and its use will require aircraft redesign and the need for very significant investment in infrastructure and storage.   The DfT itself acknowledges:

"… the timelines for zero emission flight are still uncertain and depend on continual progression in battery, fuel cell and liquid hydrogen propulsion technologies. There is currently limited available evidence on the costs of these technologies"

6.2   According to the industry body Sustainable Aviation ('SA'), there is an "urgent" and "desperate" need for government support to help develop the required new technologies.  The amount said to be needed is £500 million which SA says would be matched by a similar contribution from the industry.[24] By comparison, the DfT has promised £15 million.

7.       Conclusions

7.1   The DfT contends that: 

“The Jet Zero Consultation sets out the principles for delivering aviation net zero by 2050 and outlines the range of solutions needed to reach this goal."[25]  and               

“The scenarios show that significant in-sector abatement could be possible if we make substantial progress with new technologies. However, making the required technological progress will be very challenging and there are many barriers that will need to be overcome…” [26]

                   [Emphasis added]

7.2   Setting out principles and outlining solutions is commendable but positive action is also needed. The climate crisis is urgent and critical and the solutions need to reflect that.

7.3   Further evidence of the DfT's tentative approach are the following additional caveats:

“The scenarios presented here are not prescriptive. The uncertainty surrounding the future costs of the measures mean that it is not possible to assess the relative cost effectiveness of the scenarios. The optimal mix of measures will become clearer over the coming decade as the relevant technologies mature and evidence of their relative costs improves.”

                   …

“There is significant uncertainty surrounding the abatement potential, uptake and costs of the measures described in this document and therefore these scenarios should be seen as illustrative pathways rather than forecasts.”[27]

                   [Emphasis added]

7.4   Put shortly, the DfT's approach is so full of "ifs" and "buts" that it can hardly be described as a strategy.  Whilst stating that the objective of net zero “must be achieved” the tentative and speculative nature of the DfT's approach does not inspire confidence, and there is almost nothing in the DfT's proposals to incentivise development of the necessary technologies.  Moreover, there is no fall-back position in the event of a lack of progress.

7.5         The DfT's position can be characterised as supporting 'business-as-usual' whilst hoping that technological solutions emerge in the next 20-30 years, even though there is a high level of uncertainty about the feasibility, costs and timescales of the technological solutions being relied upon.

7.6   It is not clear that the DfT has taken account of the fact that, with an economic lifespan of 20-30 years, many (possibly most) of the aircraft coming off the production line now and on order books will still be flying in 2050.

7.7   We are particularly concerned that the DfT's approach is heavily backloaded with very little progress projected until the 2040s.  It is all too easy for a government department to commit to a target without any clear means of delivery, especially when the results will not be known until well beyond the tenure of any government minister, or indeed of any government. On such a critical issue, there needs to be clear evidence of early progress so that the problem is not simply passed on to future generations.

7.8   We are also concerned that the DfT intends to review progress only every five years, and for SAFs the first progress review is not intended until 2030.  It cannot be right to wait until 2030 before assessing whether the strategic objectives are being delivered.

7.9   There needs to be a more measured strategy from the outset, similar to the 'Balanced Net Zero Pathway' proposed by the CCC which, in our view, has a far more realistic prospect of success. The industry would then have a clear incentive to decarbonise, knowing that its future growth prospects depended upon achieving a trajectory towards Net Zero by 2050.

7.10     We would urge the DfT to reconsider the approach recommended by the CCC rather than adopt a strategy of hoping for the best.  As noted by the World Economic Forum (‘WEF’)[28] and referred to by the DfT in its Evidence and Analysis paper, “Hope is not a strategy”.

Stansted Airport Watch

September 2021

Annex A

Extract from DfT 'Making Best Use' Policy Document[29]