UK Civil Aviation Authority              ZAS0060

Written evidence from the Civil Aviation Authority

Introduction

1. The UK Civil Aviation Authority (CAA) welcomes the Environmental Audit Committee’s inquiry into net zero aviation and shipping.
2. As the UK’s independent aviation regulator, we will focus solely on issues related to net zero aviation and have approached our response from two stand points:

• The first is from the perspective of our current statutory duties, which for most of our regulatory activities are about a safe and secure aviation system that supports an open and competitive market, which serves and protects the interests of consumers.
• And secondly, from the perspective of the wider challenges for the sector in addressing its carbon performance. These go beyond our current statutory duties but point to the need for the sector to change to secure its long-term viability and health. Depending on the priority afforded to the net zero objective by the government, the policy choices required to implement it may have implications for access to the aviation market and therefore competition within it. This may in turn have implications for how we interpret “consumer interests” in the longer term if, without further action to decarbonise the sector, the open and competitive nature of the aviation market and its ability for consumers to access it is challenged.

3. Where appropriate for the CAA to comment, we have set out our response to the questions raised in the inquiry below. For clarity, given the medium to long-term nature of the measures detailed in our response, we have responded on the basis of aviation traffic levels being at pre-pandemic levels.
4. It is also worth noting that this response reflects our current policy positions. We are committed to continuing to update our approach to the environment and our position will develop as net zero aviation evolves.

CAA responses to inquiry questions

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

5. Operational efficiencies can make a practical and immediate contribution to reducing emissions from aircraft. We therefore agree with the government’s approach, outlined in its Jet Zero Aviation consultation, to reduce CO2 emissions by increasing the efficiency of our existing aviation system, through improving the efficiency of aircraft and how they are operated, changing how airports operate, and optimising the use of UK airspace.

Improving the efficiency of aircraft and how they operate

6. One way of improving the efficiency of how aircraft operate will be through ending the practice of carrying more fuel than is necessary for the safe execution of a flight, known as tankering. This would reduce both CO2 emissions and enable better utilisation of the limited supply of sustainable aviation fuels (SAF). It is important to recognise that there are often a range of factors influencing operators’ approach to tankering. These include turnaround times at remote airport locations, cost considerations both in terms of supply of fuel at the down route airport and airspace routeing considerations, as well as carrying a minimum amount of surplus fuel for safety reasons. For this reason, we support a voluntary approach to ending tankering at this time. We note this policy might have an impact on ticket prices if it leads to higher net fuel prices for carriers.
7. Making flight routes more direct can also reduce emissions. An example of where we have recently seen such carbon reduction benefits includes the UK’s work with neighbouring states to improve international flight trajectories. EUROCONTROL, which is responsible for the central coordination of air traffic control in Europe, has worked with its member states, including the UK, and other stakeholders to loosen the restrictions placed on operators to fly particular routes during the pandemic. This resulted in a significant reduction of nautical miles flown by aircraft. The relaxation of these restrictions is set to remain in place until 4 November 2021. Ongoing support from all EUROCONTROL member states for extending this and making these measures permanent would be welcome. We do, however, acknowledge that as traffic reverts to more normal levels and the air traffic network becomes more intensively used, it may not be possible to continue to deliver the full benefits seen during the pandemic.

Improving how airports operate

8. We support the government in setting challenging targets for decarbonisation. Further work will be required to determine precisely which airports are in scope and whether the policy would apply to smaller UK airfields that deal primarily with recreational aviation.
9. To help achieve the target of zero emissions, we believe that a number of wider potential policy interventions may need to be considered at a point in the future, including a range of market based measures and incentives and potentially reforming the airport slot system so that it no longer solely focuses on maximising capacity.
10. Slot reform would represent a major undertaking, in part because of historically acquired slots and the global nature of how airport slots are administered. However, the government could consider offering some informal guidance about increasing the priority of environmental performance through reducing ground and airborne holding.
11. In addition, changes to Air Navigation Service Provider (ANSP) charging could also be considered. Airports that establish their airport access/ANSP charges already have broad discretion to set charges for airlines, so it is possible that those operators could be “encouraged” rather than that just “permitted” to establish such charges for more inefficient aircraft. One way to support this policy might be to establish a standardised carbon rating for specific classes of aircraft and publish a table of which operators have such a charging scheme. We would be willing to support providing such information. In addition, the charges that airlines pay to NATS for operating flights over the UK could incorporate a stronger environmental incentive.

Optimising the use of UK airspace

12. By improving the efficiency of UK airspace, we can make an important contribution to mitigating the environmental impact of aviation. For the CAA, our role most closely linked to this ambition is our co-sponsorship with the DfT of airspace modernisation, the key tenets of which are outlined in our Airspace Modernisation Strategy. One of the overall objectives of this strategy is for cleaner journeys, and the emissions savings that modernisation can deliver are a key component of the UK’s commitment to reach net zero by 2050. NATS’ feasibility study[1] into airspace modernisation estimates savings of up to 10-20% on fuel burn and CO2 emissions in south east England, where the airspace is most congested. The aviation industry’s decarbonisation roadmap[2] also suggests that air traffic management and operational improvements are likely to reduce CO2 emissions from UK aviation by around 4.6% by 2050 relative to 2016, with the potential for additional savings from future innovations.
13. Beyond airspace modernisation, we are also the decision maker for proposed changes to the design of UK airspace. To help us improve operational efficiency through optimising the use of UK airspace, several further changes should be considered. The first would be for the government to amend the environmental guidance it provides for airspace decisions.
14. At present, section 70 of the Transport Act 2000 and the associated environmental guidance from government requires the CAA to balance different factors in reaching airspace change decisions, other than safety which is the top priority. This requires a balance to be struck between generating airport capacity, providing airspace access for other users and mitigating externalities such as noise, carbon and air quality. One option open to the government would be to ask us to give greater weight to one of those factors (such as carbon reduction) in approving those decisions. It is worth noting that in doing so, one consequence might be to reduce the benefits delivered against the other factors. For instance, a more efficient (i.e. shorter and more direct) flight path might generate different noise distributions for overflown communities.
15. Our core statutory duties cover safety, security and consumer interests. In aviation legislation, we are only required to consider environmental impacts in our decision making in relation to our airspace and space functions. We are, however, subject to some cross-cutting duties (e.g. to consider biodiversity) in more general environmental legislation. As the industry’s regulator, we expect to take a leading role in enabling the delivery of decarbonisation and overseeing performance. As part of scoping this role alongside government, we are open to a discussion about whether r a change to our statutory duties could have a meaningful impact on carbon reduction and other aviation impacts, without creating undesirable outcomes.

How close are zero carbon fuels to commercialisation for aviation? How effective will the Jet Zero Council be in catalysing zero emissions technologies? What role should transitional fuels such as alternative hydrocarbon fuels play?

16. Using SAF to replace traditional kerosene appears to be the best short-term option to start a major reduction in CO2 emissions. However, to realise these benefits, SAF will have to be adequately commercialised for the aviation industry.
17. Current SAF production capacity is around 0.1% of global annual jet fuel consumption. The SAF production sector would need substantial investment to move that capacity forward and there may be other factors to considers with such a large increase in capacity. The best estimates from the World Economic Forum, based on current trajectory, is that production in Europe could get to around 7% by 2030. Production would need to continue to grow by 15% compound to get to 100% by 2050, assuming that other technology efficiencies are brought in to compensate for the growth in aviation over the same period. This rate of change would fall short of the 78% reduction in emissions by 2035 target.
18. Market-based measures and capital investment may be needed to incentivise and invigorate UK-based production capacity, so that we can achieve the net zero domestic target for 2040. This could be coupled with:

• effort and resources to drive forward the development of a comprehensive global regulatory standard / sustainability criteria for SAF, which would need to be stronger than the current ICAO standard as it allows for the use of land for crop-based feedstocks;
• frequent and specific targets and milestones, to ensure progress is monitored and outcomes realised; and
• the establishment of routes to give SAF use based on availability of fuel supply, to avoid unnecessary shipment of fuel.

19. In considering the approach to SAF, it is also worth bearing in mind the emerging evidence that SAF may also contribute to reducing non-CO2 impacts of aviation on warming as well as reducing CO2 emissions.
20. Careful consideration should also be given to the use of hydrogen fuel since burning it at altitude contributes to global warming.  The alternative of using hydrogen to feed fuel cells on the ground, and those fuel cells are then carried in the aircraft to power it is a much more desirable approach.

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?

21. Advancing the readiness and maturity of the net zero technologies is of prime importance and government-backed measures to support these activities will be extremely beneficial. Our role here is to work with government and the sector to help deliver the ambition of making the UK a leading country for low carbon aviation innovation and manufacturing. This includes supporting the Jet Zero Council through advising on regulation and aircraft certification for new types of aircraft required to deliver net-zero aviation by 2050, and designing regulatory frameworks for the safe introduction of new technology. We have also developed an approach to dealing with innovators and emerging technologies, which we have used in support of UKRI’s Future Flight Challenge. This has showcased the integration of net zero aircraft using hydrogen, fuel cells and battery technologies into the existing aviation ecosystem.
22. We welcome government's intention to set a trajectory for CO2 emissions reduction to 2050 and to put in place appropriate reviewing mechanisms. We believe a single roadmap would help provide clarity and consistency in messaging across relevant strategies and government work programmes to help industry and regulators to understand the direction towards zero emission aviation in the context of the government’s broader Future of Flight and unifying Future of Transport objectives. We would be keen to support the creation of such a roadmap.
23. Furthermore, the continued use of government’s convening authority and leadership would aid in drawing together stakeholders to address the complex challenges and problems for consistent transition in future.
24. It is worth noting that the majority of aviation CO2 emissions come from long-haul aircraft where it may not be possible to transition to battery/electric propulsion (certainly in the short-term) and the extent to which hydrogen may be able to play a role is unclear. For these long-haul flights there is a clear need to support the uptake of SAF. Policies on reserving sustainable fuels for aviation where the net benefit to carbon reduction could be largest would also help support this.

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)?

25. As the UK’s independent aviation regulator, we fully support greener aviation but also recognise that UK aviation is a significant driver of economic growth and people will continue wanting to fly. We support an approach that sees consumers making greener flight choices and the industry incentivised to reduce emissions to deliver this.
26. Measuring progress against a series of KPIs and associated strategy reviews would provide a vehicle for considering whether sufficient headway is being made towards the net zero outcome, and whether further consumer education, behavioural change or market-based measures are required. Given the uncertainty in how effective other policies will be, we believe it is appropriate to start considering and designing those potential mechanisms – particularly market-based measures which may reduce carbon emissions while not necessarily directly limiting consumer demand. This could include measures focused on incentivising aviation businesses, for instance. While such approaches may not be appropriate to adopt today, they should be ready to adopt swiftly if progress monitoring suggests they are required.
27. While not sufficient on its own, providing consumers with more information on aviation’s impact on the environment to enable them to make better-informed decisions is an essential policy position for us at the CAA. We therefore welcome the government’s proposals to explore ways to do this, including potentially mandating the provision of environmental information. This supports the research work we have recently undertaken about consumers’ attitudes to carbon performance information in the aviation sector in support of its current Environmental Information Duties (section 84 of the 2012 Civil Aviation Act).
28. Providing consumers with clear information on the impact of their flight on the environment is a useful and speedy nudge policy measure, while the medium to long-term interventions are in the development phase. To this end, we carried out a piece of deliberative research to understand better the connection consumers have with the environment in aviation. The insights from this work indicated that participants thought emissions information should be universally provided across all sectors, even though price and convenience might still be the main decision drivers. Participants also tended to see this information as having the purpose to both inform the public about the relative impacts of flying and hold airlines accountable for their environmental impacts, encouraging them to reduce emissions. Evidence of more consumers making air travel choices based on the carbon performance of different airlines would send a powerful commercial signal to airlines and further incentivise the introduction of lower carbon technologies.
29. To achieve this, information will need to be standardised, accurate and vetted (improving trust for consumers) so that it is meaningful and comparable. It will have to be available as part of the flight search and individual airline booking systems to enable the consumer to consider relative not just absolute performance. It should also apply to all commercial airlines using UK airspace, not just UK airlines. Otherwise, consumers would only have partial information and the UK aviation sector could be at a disadvantage relative to its international competitors. 
30. We expect to work closely with government and other stakeholders in developing proposals to meet these objectives, and to address some key areas of contention – for instance how carbon offsetting is treated in any metric.  Such work could be included within a wider campaign to educate the public about the levels of carbon produced by different day-to-day human activities and the relative carbon performance of different modes of transport.
31. The other key dimension to consider in this work is whether the UK and international aviation industry will cooperate in the provision of information in a comparative way, or whether some stronger powers would be required to mandate this provision. More broadly, long-term and persistent government-led non-sector specific public education on decarbonisation is needed to set the example for the UK public to follow. This will give consumers and the public the wider context to inform their decisions relating to aviation, and further raise awareness, an essential first step in helping people to make more sustainable choices. 

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

32. Both ICAO and the UK government will need to focus on developing an international approach if the government is going to achieve its goals of decarbonising domestic and then international flights from the UK by 2040 and 2050.
33. Practically minimising aviation’s impact on climate change is a global issue and must be solved by through international cooperation, standards, and target alignment.
34. An example of where international cooperation will be important can be found in the development of a comprehensive global regulatory standard / sustainability criteria for SAF. This needs to be far stronger than the current ICAO standard as it allows for the use of land for crop-based feedstocks.
35. While it would be for ICAO and government to outline how the international approach to zero carbon aviation would look, we look forward to working with them on its development.

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?

36. Aviation is inherently international, and any move to standardise environmental reporting should be welcomed. The UK government played a leading role in the development of the CORSIA scheme, and the CAA remains committed to supporting its implementation.
37. In addition, we strongly agree with the approach set out by the government in its Jet Zero Aviation consultation, to use both carbon markets and greenhouse gas removals (GGR) to reduce CO2 emissions. We believe both have a role to play in reaching net-zero aviation as it is unlikely there will be sufficient offsets available to fully offset aviation’s emissions. This was noted by the Committee for Climate Change.
38. Furthermore, we welcome the government’s intention to set a CO2 emission reduction trajectory to 2050. This would provide government with targets against it can measure the effectiveness of any policies, and help aid our understanding of which interventions work, whether they need to be bolder or whether alternative solutions are required.
39. With regards to addressing carbon offsetting within the proposed trajectory, there are complexities, benefits and disbenefits regarding incentives and accountability mechanisms in both the in-sector CO2 and the net CO2 approach. The in-sector approach would not consider offsets in targets, and would therefore provide the strongest incentives for the sector to decarbonise. This approach would signal to the industry that reducing emissions is the ultimate goal, and offsetting cannot be the primary mechanism for achieving this. We would welcome this signal to the industry.
40. That said, if all measures described in the government’s consultation are implemented in full, it is still possible that there would be, for a period at least, remaining emissions to offset. By using the net approach to measuring targets, the government would be recognising the reality that some offsets may be required (whichever trajectory is chosen). This would create the need to focus on establishing a common standard and transparent report on the efficacy of offsets, for example by following the existing UN Gold Standard certification. In turn this could improve trust with consumers and encourage more positive travel choices, including passengers deciding to offset the carbon emissions of individual flights.

Conclusion

41. We trust the Environmental Audit Committee finds our response to its inquiry helpful. Should the Committee wish to discuss anything further, we would be happy to do so.
42. We look forward to working with the Committee and all other aviation stakeholders on how best to deliver a reduction in emissions from the aviation sector to achieve the aim of net zero.

Civil Aviation Authority
September 2021