NATS                            ZAS0058

Written evidence submission by NATS
 

Introduction

1. NATS is the UK’s leading air navigation services specialist providing, under license, en route air traffic management services over the UK and eastern North Atlantic from centres at Swanwick, Hampshire and Prestwick, Ayrshire.

2. In addition, we are contracted to provide air traffic control services at 14 major UK airports.  We also have a focused international growth strategy centred on those areas of the world, notably Asia Pacific and Middle East, where rapid and significant growth in air traffic is causing complexity and delay, playing into the particular expertise for which NATS has a global reputation in our industry.

3. Airspace is a critical pillar of UK national transport infrastructure supporting the wider economy. It enables the safe and efficient passage of aircraft, connectivity with markets across the globe, goods to be transported, and supporting tourism.
    
4. Reducing the aviation industry’s carbon footprint is one of the biggest long-term challenges we face.  NATS fully supports the commitment to achieve net zero carbon emissions by 2050.  With sustainable fuels and electric aircraft still some time away from being an everyday reality, how we manage our airspace can play a crucial role in reducing CO2 emissions.
    
5. The aviation industry remains committed to achieving net zero emissions by 2050, and fully recognizes that failure to decarbonize is not an acceptable option.  UK aviation is targeting at least an overall 15% reduction in net emissions by 2030 (relative to 2019), and a 40% net reduction by 2040, with the pace of decarbonization ramping up as new technologies and fuels become mainstream in the 2030s.  With the right Government support, the industry can decarbonize and continue to provide valuable jobs and services across the country.
    

CONSULTATION QUESTIONS

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

• Airspace is critical national infrastructure that has not been fundamentally upgraded since the 1950s.  In the short-term, modernising UK airspace and enabling more efficient flight profiles offers the greatest opportunity to reduce UK aviation emissions, while more longer-term technologies are being developed.  It will generate significant carbon savings through more efficient flight profiles, fewer miles flown per aircraft, less airborne holding, and less fuel burn – quicker, quieter, and cleaner flights. Current aircraft capabilities already far exceed the operational opportunities for enhancing efficiency because of the constraints within the UK’s highly complex airspace, so completion of this vital programme must be a top priority.

• It will take at least 5 years to implement new sustainable aviation fuel (SAF) policies and have initial plants operational, while next generation aircraft technologies are not expected until the mid-2030s.  It is critical, therefore, that the delivery of airspace modernisation is a top priority for the Government and industry, and any potential barriers or delays to progress are quickly identified and resolved. 

• The adoption of airspace modernisation as Government policy, and sponsorship of the Airspace Change Organising Group, was a vital step in ensuring the benefits of this programme can be realised.  It is now crucial that the Government continues to push the project forward and maintain momentum.  Funding support in the years 2020/21 and 2021/22 has been welcome and will help the sector to push ahead with modernising airspace despite the impact of Covid.  However, with flights still around 50% of 2019 traffic levels it is clear that the recovery from Covid will take a long time.  Continued support from the Government, through providing the remainder of the bridge funding this year and continued support beyond 2021/22, will therefore be required if the benefits of modernisation are to be realised in the desired near-term timeframe. 
   

2.              What new technologies are there to reduce emissions from aircraft

• NATS is currently required to measure and incentivise airlines that depart on time.  With more advanced traffic management tools that now enable us to absorb delay in the more fuel efficient and less congested cruise phase of flight, this regulation should be changed to measure and incentivise airlines to arrive on time.
  
  Thanks to research conducted within the Single European Skies ATM Research Programme, NATS has developed an innovative new collaborative air traffic management procedure called Cross Border Arrivals Management (XMAN), which enables more predictable, fuel-efficient and environmentally sensitive flights that give airports a greater degree of predictability on when flights will arrive.  It works by sharing information between NATS and surrounding Air Navigation Service Providers who work together to slow down the aircraft during the en-route phase, at a higher altitude where it operates more efficiently, ultimately reducing the holding times for arriving aircraft.  XMAN has demonstrated that by absorbing just one minute of delay during the en-route sector of the flight, called ‘linear holding’ – rather than in an orbital holding stack – aircraft can reduce CO2 emissions by c15,000 tonnes a year.  While this work has been conducted within SESAR, it would be beneficial for the scope of the Aerospace Technology Institute’s ‘Fly Zero’ project to be expanded to include the next phase of improvements to this tool in the UK.
   
• NATS would welcome a study into differential charging as a mechanism for reducing aviation emissions.  There is potential for reducing carbon emissions through encouraging lowest emission route selection, and penalising operators that flight plan for minimum cost rather than minimum emissions.  However, any differential charging mechanism would need to be implemented in the context of the overall charging system to avoid inconsistency that could be damaging to UK aviation vs non-UK carriers.  It should also be noted that in the long-term the increased cost of SAF and carbon removals will naturally tend operators to the fuel minimal route, at which point the need for differential charging may be negated. 
   
• Measurement of contrails and their climate impact has been the subject of much research in recent years, and NATS is closely involved in several projects looking at the optimisation of flight plans to reduce overall non-CO2 effects.  A recent study by researchers at Imperial College London suggested that changing the altitude of just 1.7% of flights by 2,000ft could reduce contrails’ climate impact by nearly 60%.  NATS has been working with Imperial and the German Aerospace Centre (DLR) to further investigate the link between where aircraft fly and contrail formation in the airspace we manage, and we hope to understand how we could implement avoidance strategies without increasing fuel consumption and CO2 emissions.
  
  By predicting where supersaturated air is going to form over the Atlantic and using Oceanic flight data, research can investigate the possibility of avoiding these areas, either by airlines flight planning around them or by managing air traffic flows tactically to minimize contrail formation.
  
  There is clear potential for benefits to be found in this area, but much more research is needed into the ways in which those benefits can be realised without compromising safety.  Projects analysing this are progressing in both the EU and the USA, and in our view the UK Government should support further targeted research.  Government sponsorship and funding of such research would be extremely beneficial in ensuring it can be properly analysed and factored into the decarbonisation roadmap.
  
   

3.              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 aviation?

• NATS agrees with the principle of setting a UK aviation CO2 emissions reduction trajectory to 2050.  However, the complexity of decarbonising aviation means it is not on as predictable a trajectory as other modes of transport, so should be provided with a supportive environment in which to make this transition rather than having targets imposed which may not be achievable.  The industry’s ambition is most certainly there, but its finances have been decimated by the pandemic and that must be factored into the Government’s ambition.
   
• Work already undertaken – such as the Sustainable Aviation Decarbonisation Roadmap – makes it clear that the trajectory to net zero is not a straight line.  The lead times on new technology for aviation mean that the pace of decarbonisation will start slowly and speed up over time.  Significant policy and investment must be delivered by 2030 to bring each of the decarbonisation solutions to full maturity, in order to be rolled out in the 2030s and 2040s and meet the net zero target by 2050.  Any delay in the early part of that trajectory could risk missing the 2050 net zero target. 
   
• By far the greatest carbon savings can be achieved with the next generation of aircraft and sustainable aviation fuels; but on a commercial scale these are still some years away.  More immediately, airspace modernisation can start to deliver benefits and as this programme is now Government policy, Government must therefore focus on support that ensures the completion of this programme, as well as on enabling investment in aerospace technology, infrastructure and mandates on sustainable aviation fuel and carbon removal.  Without this support, the net zero target will simply not be achievable.  A provision of this top-down target should be that it does not lead to competitiveness or carbon leakage risks and should be pursued in parallel with international approaches to reduce emissions.
  
   

4.              What further action is needed by the International Civil Aviation Organization to drive emissions reductions? What can the UK Government do to drive international action on emissions?

• The best pathway to net zero is by using our international leadership to secure a long-term aviation goal aligned with the Paris agreement, without which there will be the potential for market distortions and carbon leakage.
   
• A global baseline for fuel efficiency and a clear, long term CO2 target for global aviation, which is compatible with existing commitments, is ultimately required and ICAO should be central to delivering that.  The 2022 ICAO Aviation General Assembly should be used as an opportunity to agree that, and UK leadership will be absolutely necessary.
  
  ICAO should also be providing regular guidance to states on implementing operational efficiencies, though we feel they could be doing more to provide this guidance, and the UK Government should encourage them to do so.

September 2021