Written evidence submitted by the RABA Group[1] (AIS0010)

The Group’s overarching aim is to ensure the strategic importance of the UK’s smaller and business airports and the economic value they create at a local, regional and national level is understood and recognised by Government, regulators, local authorities, shareholders, investors and other key stakeholders with a view to positively influencing the commercial, regulatory and reputational environment within which its members operate.

Contents

What has been the effect of the coronavirus pandemic and reduced flights on Scottish airports and local communities, including tourism?

Transport Scotland Interventions During the Pandemic

Caithness and North Sutherland and Wick John O’Groats Airport loses air services

Proposed Skye Air Services to the Central Belt

Inbound Tourism

How do airports support the local and regional job market?

General Aviation Airports

How effective is the movement of air freight for essential supplies in rural or isolated airports?

Is there a sufficient level of investment in the infrastructure around airports in Scotland?

Coronavirus: NI Domestic Aviation Kickstart Scheme

Aims of the scheme

How will airspace modernisation affect Scottish airports?

What schemes are in place to reduce the carbon footprint of airports?

The SATE Project

Different Types of Aviation have Very Different Current and Prospective Carbon Footprints

RABA Group Multimodal Carbon Assessments

Whole of Life Transport Infrastructure Costs and Emissions

Reservations about the 2017 DfT Passenger forecast model

Radiative Forcing

Fly Local

Airfreight Considerations

Business Aviation

Emerging Technologies

Appendix 1 - The Multi-Modal Carbon Assessment Model (MCAM)

Appendix 2 - Some Domestic Route Emissions Modal Comparisons

Appendix 3 - Reservations about the 2017 DfT Passenger forecast model

Appendix 4 - Catchment Leakage Counter-Factual

What has been the effect of the coronavirus pandemic and reduced flights on Scottish airports and local communities, including tourism?

Transport Scotland Interventions During the Pandemic

Our understanding is that the Scottish Government helped underwrite air services during the worst of the pandemic, and that this was a valuable intervention, at a critical time. Unlike their English counterparts, they also suspended Business Rates payments for Scottish Airports – a pragmatic response to the lower level of utilisation of airport rateable assets and welcome step. Throughout, the Scottish Government has displayed a greater recognition of the importance of aviation, and particularly smaller airports, to supporting Scotland’s economy and have acted accordingly, whilst also taking a more cautious and independent approach on travel restrictions to the UK Government.

Recommendation: The Committee could usefully acknowledge Scottish Ministers willingness to intervene positively to support the sector and suggest that they continue to do so in a carefully targeted way to assist its post-pandemic recovery.

Caithness and North Sutherland and Wick John O’Groats Airport loses air services

Caithness and Sutherland is the most peripheral part of mainland UK.  It has significant geographical challenges as to its effective integration into both Scottish and UK national life.  

Since Covid the air services between Wick John O’Groats Airport (WJOG) and Aberdeen and Edinburgh have been suspended with little prospect of adequate frequency being delivered by the open market, or in the foreseeable future. 

Where market failure demonstrably exists as defined in the EU PSO regulations, Highland Council decided to explore instituting Public Service Obligations on the two routes.   In this case market failure is where air (and transport services generally) are not providing the connectivity that serves the growth needs of the airport catchment area. Local stakeholders have significant concerns about their loss of air service provision.

Highland Council has concluded that Caithness and Sutherland requires an adequate level of air services to both Edinburgh and Aberdeen Airports.  This can likely only be properly secured by way of a Public Service Obligation (PSO) underwriting good air connections with more than one metropolitan centre (i.e. the Scottish national capital of Edinburgh, and its the energy capital at Aberdeen).

These realities feed through to transport provision with significant terrestrial transport challenges involving long transit times to key Scottish destinations, low public transport service frequencies and occasional weather disruption in the winter. Inverness Airport is 2½ hours from Wick by car, and 5½ hours by rail and more than 4½ hours by coach (with changes in Inverness town centre).  Car drivers have to allow around 6 hours to drive to Edinburgh and 5 hours to Aberdeen.  Public transport times are significantly longer.

The small local population (and hence constrained local market), and the nature of the area’s economic assets mean that key economic sectors and employers are outward facing. That includes major inward investors such as Rolls Royce.  They rely on good transport links and air services in particular - to maximise the benefits of the local economy’s assets, despite its remote location. However, the major local employer (Dounreay nuclear site) will be greatly reduced in size over the years to 2032. To counteract this, recent and new initiatives such as renewable energy, the North Coast 500 tourism route, and the Sutherland spaceport are being taken forward.

Highland Council have been tasked with trying to organise PSOs for these two routes, and Transport Scotland have publicly pledged £1m/year towards them.  However, detailed studies suggest that finance nearing £2-£3m/annum will be required (especially during the Covid Recovery period).  There is a danger that sloping shoulders may be at work in different departments to avoid their budgets being committed. 

Recommendation: Anything the Committee can do to ensure that adequate funds are made available once requisite subsidy amounts become apparent (during the current tendering process) would be hugely valuable to securing these important links.

Proposed Skye Air Services to the Central Belt

The position of interested stakeholder partners (HIE, Highland Council, HITRANS) remains as per their most briefing paper[2] and also recently published Skye Investment Plan which highlights that Skye is only regional centre where a day trip to central belt is not possible by any mode and air offers the only solution.  Therefore, when general demand recovers post pandemic, partners should continue to explore opportunities to develop an exemplary and cost effective model of a net zero regional airport at Ashaig, that initially would look to operate scheduled services using Twin Otter or equivalent aircraft, but moving to next generation clean-fuel aircraft as soon as the technology is available and certified.  It was estimated that the reintroduction of scheduled flights could attract up to 15,000 passengers every year and provide a significant boost to the local economy. We believe that this is an under-estimate and that the introduction of such services would be a significant boost to the economy of the Island and those parts of the mainland that are connected to it, including the proposed rewilding project inland.

As the Skye investment Plan notes, “As travel demand increases following the pandemic there is an opportunity for Skye to improve its connectivity with strategic centres in an environmentally and economically sustainable way by being at the forefront of new technologies in the aviation sector. The Scottish Government has established a vision for the Highlands and Islands as the world’s first net zero aviation group and trials using hydrogen and electric are already at an advanced stage with the type of aircraft which could be used a passenger service between Skye and the central belt. Local partners have already undertaken detailed appraisal to establish the necessary infrastructure upgrades required at Ashaig in order to obtain the necessary operating licences for scheduled flights to be reintroduced for the first time since 1988.”

Several efforts have been made to review how new technologies could be applied to the airfield to minimise cost and improve resilience and safety for the introduction of scheduled flights.  HIAL have expressed interest in managing the airfield should scheduled services be re-introduced and view it as a welcome blank sheet onto which to apply innovation with few legacy issues.  A consultancy report also focussed on innovative ways of interpreting aviation regulations and developing phased plans leading towards a successful reopening.  For example, according to the Skye Air Services Business Case 2016, the airport would be required to have a single Cat 3a standard Rescue and Fire Fighting Services vehicle with garaging facility, storage, and basic non-residential staff facilities. However, as the airfield was not required to host the fire and rescue team on site, it was noted that sharing the local squad facilities at a nearby shipping yard would help to reduce costs when it came to staffing and residential maintenance.

The Stakeholder Briefing Note of Feb 2019 summarised things thus; “Extensive work has been undertaken on the business case for restoring scheduled air services to Broadford Aerodrome, Skye.  These studies concluded that investment would be needed in upgrading infrastructure facilities, such as for the terminal, aprons, airfield lighting, road access and car parking to enable scheduled air services to operate.

Based on a number of performance indicators, Option A.2 (continued use of the existing airstrip, with the terminal, apron and other associated facilities sized to accommodate a 19-seater aircraft such as a Twin Otter between Glasgow and Skye with GPS technology to support Instrument Approach Procedures (IAP) to the airport) was recommended as the most deliverable proposal and represents the minimum capital investment needed to the existing airfield to accommodate a 19-seat aircraft.

During 2018, HITRANS commissioned further work (see referenced above) which undertook an analysis of best value options to obtain the necessary licenses for the re-introduction of air services and upgraded airport facilities on Skye to introduce services in the short term. This work identified that this could be achieved for capital expenditure of between £1,530K - £1,770K.

The annual operational costs for the airport are estimated at £320 - 380K. On the basis of most staff performing dual role functions. Finally, work has been undertaken to review the most suitable mechanism for supporting scheduled air services. From an airline perspective, a Public Service Obligation (PSO) support is deemed the most suitable and state aid compliant mechanism to allow a trial operation given the requirement for additional assets to fly the schedule and the lack of recent history of operation on the route. Moreover, the PSO would provide certainty in terms of operation and of course fares. Analysis considering an operation with a frequency of 12 rotations per week and an annual traffic level of 15,100 passengers estimates that the level of subvention required would be in the order of £450k per annum for the operation and in addition to the operating costs of the airfield.”

A number of related reports and studies have been completed, that put forward the business case for the reopening of Skye Broadford and outline some expected costs of doing this;

-          November 2018 Analysis of Best Value Options To Deliver Air Services To An Upgraded Broadford Airport on Skye

-          November 2016 - Skye Air Service Business Case

-          March 2013 - Skye Air Service Feasibility Study

-          Jan 2016 report Economic and social benefits of proposed air services at Skye Airport

-          Air Services from Skye: Assessment of Proposed Services

-          Review of Air Services in the Highlands and Islands – undertaken on behalf of HITRANS ZetTrans (final report dated February 2010) - Part 1 –Air Service Options

-          Ashaig Airstrip Runway Development Options – undertaken on behalf of HITRANS by Mott MacDonald / Franklin and Andrews (final report dated March 2007)

-          HITRANS by Steer Davies Gleave (final report dates November 2004)

Note:- Runway development options were investigated in some detail in 2007. This work has to an extent informed the options that exist in terms of increasing runway capacity. At that time, it was understood that a Precision Approach Runway would be preferred, which would support installation of an Instrument Landing System. The increasing adoption of LNAV/LPV-based approaches meant in the earlier study that would not now be the case, and a Visual/Non-Precision Approach runway with LNAV/LPV approach was considered sufficient in 2013.

Recommendation: The Committee would play a useful role in encouraging an update and revisiting of this body of work and possibilities as the economy moves out of the pandemic.

Inbound Tourism

RABA’s anecdotal evidence is that staycation tourism has replaced in large part the short and long-haul tourism within the Highlands.  This has been good news, but the less welcome news is that domestic tourism and terrestrial delivered tourism has less spend per visitor than international tourism.   Using some historic figures from the National Connectivity Taskforce[3] it was found that on a UK wide basis.

• 75% visitors come by air but represent 85% of spend
• Long haul only 15% of visitors but 40% of spend (Long haul: £1,159 vs Short haul: £492 Domestic: £187)
• Long haul/short haul relative balance and spend have not changed since 2007 (2014)
• Most of those on holiday visit only one UK region during their trip
• London enjoys 54% of UK visitors because LHR, LGW and STN are main UK entry points)
• Hence if Scotland wants to attract more long haul/short haul international visitors it needs to improve its own direct links to key markets alongside ensuring connections to Scotland over Heathrow and other important EU hubs operate effectively.

In Scotland, 14% of the workforce is engaged in tourism representing 100,000 FTE jobs and serving 50 million visitors.  The industry contributes USD 4,800 per head of population for Scotland.  Overall, 85% of visitors are from the UK and 15% are international, but the international visitors represent 35% of the revenue. (Source: VisitScotland)

In the Republic of Ireland 75% of overseas tourists arrive by air and 25% by ferry, whilst 60% of overseas Northern Irish visitors come by air and the balance of 40% by ferry. (Source: Tourism Ireland)

In some research for the UK Connectivity Taskforce report (Paper 7) data was assembled that demonstrated:

•         80% of tourists do not stray beyond two hours from their arrival airport.

•         UK Regions need convenient access to an international hub so long haul tourists can access those regions.

How do airports support the local and regional job market?  

RABA Group do not have specific Scottish specific figures but the attached powerpoints (prepared for the Aviation 2050 consultation of DfT in 2018) do provide the general themes that should be borne in mind. 

One powerpoint focusses on RABA Group’s airports Contribution to Economic Development, whilst the other focusses on Skills and Training.  A third powerpoint entitled The Strategic Value of Regional Airports underlines and explores some of these themes in more detail.

The Scottish Committee could play a useful role in encouraging Scotland to develop more Scotto-centric data and oversight, so that clarity in policy direction could be better devised. We note for instance that the Strategic Aviation Special Interest Group (SASIG) of English local authorities is undertaking research on the Covid impact of aviation contraction on the local authorities concerned (jobs, rates etc).  Nothing similar to our knowledge is being undertaken in Scotland.

General Aviation Airports

It is noted Scotland does not appear to have any dedicated or strategic oversight of its General Aviation (GA) Airports.  The UK DfT has bolstered its team overseeing this sector and has identified Business as important component part of the picture.

Many GA airports are run by local councils (eg Dornoch, Ashaig, Plockton, Mull, Coll, Colonsay, some by benevolent individual, charities or aero club enthusiasts (eg Fair Isle, Foula, Castle Kennedy, Easter Fearn, Buchan, Glenforsa, Jura, Gigha, Bute) and some as private businesses (eg Cumbernauld, Perth, West Freugh (Qinetiq)).

In a recent study for the DFT a survey of the sector asked how General Aviation is valued:

• Airfield operators, industry bodies, and training organisations felt GA was undervalued. They stressed its importance to the UK in several ways: a source of British heritage, in particular military history, with reference to WW1 and WW2 airfields; infrastructural asset to facilitate transport and trade; opportunity for leisure in its sporting elements and as a hobby; community asset for a shared source of culture and green space.
• Participants were concerned with the ramifications of undervaluation, which they thought were: the closing of airfields and resulting shrinking of the sector; the shortage of hangarage, leaving pilots without places to store aircraft; and fewer young people entering the sector to replenish retiring pilots, instructors and engineers.
• Participants proposed several solutions to help reverse the trend, recognising that some of these were already being driven by certain parts of the industry, including: communities having a greater stake in the running of airfields; using mixed developments to provide airfields with greater financial security; greater support from DfT about the potential for GA as an infrastructural asset; independent advice for local planning authorities; and the promotion of new business ventures.

Business and Special Mission Aviation

The Regional and Business Airports Group specifically endeavours to highlight the key and often overlooked importance of Business and Special Mission aviation as a subset of UK General Aviation.

Business Aviation airports forms a distinctive functional sub-group within the RABA Group with a further sub-set being associated with Special Missions Airports. These terms are used to distinguish facilities where the following types of ‘non-scheduled’ aviation activity are in the majority:

•             Corporate, chartered and privately owned or leased business jets (Business Aviation can be characterised as the use of General Aviation aircraft for business purposes[4])
• O&G & Offshore Windfarm Support
• Military diversions, training and refuelling
• Air Ambulance & Police
• SAR and Border Force
• Borders and Aerial Reconnaissance
• Pollution Control
• Fisheries Protection
• Power Lines Inspection
• Fish Farm feeding
• Aircraft testing/type training

It is notable that Scotland is important in the context of many of these types of aviation, but their interests are often overlooked or not given sufficient attention in policy making. RABA consider it important that a Scottish Government body takes on oversight of the GA, Business Aviation and Special Mission sectors and liaises and coordinates with DfT efforts to bring some strategic co-ordination of policy, in order that it meets Scotland’s needs, not just England’s.

Recommendation: The Scottish Committee could play a useful role in ensuring Scotland’s interests in these essential but often neglected sub-sectors are appropriately safeguarded and that both devolved and reserved policy reflects this.

How effective is the movement of air freight for essential supplies in rural or isolated airports? 

This graphical overview (prepared in 2017) may provide Members with a speedy appreciation of matters (Prestwick services may need updated)

RABA Group has no awareness of special challenges in rural or isolated areas, apart from late deliveries and earlier guillotines for delivery arrivals and despatch. The introduction of drone based operations could help to improve timings and reduce the cost of servicing remoter/island areas with mail and parcel deliveries by eliminating ground truck/van based transport other than for last mile deliveries, and in so doing saving CO2 emissions as Drones will be electric rather than diesel powered.

There are, however, other air cargo related issues that do merit attention if Scottish produce is to be less reliant on using UK airports for shipment and all the additional travel/costs/CO2 that this involves. These are principally:

1. The development of more/better scheduled direct freight flights to key air cargo hubs in Europe for fresh produce (fisheries and other premier branded agricultural output) and other high value cargoes (e.g. energy and advanced engineering sector parts, IT/telecoms chips/products, pharmaceuticals, whisky). Similarly, chartered freighter operations.
2. Scottish airports developing greater capacity to handle freight so as to reduce the reliance on cross-border trucking.

Recommendation: The Committee calls for a detailed study of Scotland’s future air freight needs.

Is there a sufficient level of investment in the infrastructure around airports in Scotland? 

RABA Group would like to draw the Committee’s attention to the Northern Ireland Domestic Aviation Air Discount Scheme which was launched in the early summer to protect and enhance air services to the rest of the UK.

Coronavirus: NI Domestic Aviation Kickstart Scheme

24 June 2021

News article

Financial support scheme for airlines as they rebuild from COVID-19 and to maintain and enhance Northern Ireland's air connectivity with Great Britain

The Department for the Economy (DfE) has developed the NI Domestic Aviation Kickstart Scheme (NIDAKS) to support airlines as they rebuild from COVID-19. The scheme will also help kickstart NI’s economic recovery by maintaining and enhancing NI’s domestic air connectivity with Great Britain (GB).

Aims of the scheme

The key objectives of the scheme are to support inbound tourism and business travel (both from and to GB) and to encourage inward investment into the Northern Ireland economy.

The scheme has the following complementary aims:

1. Support basic route frequency to be maintained throughout the scheme period.
2. To incentivise enhancements of frequency above the basic route frequency.
3. To support initiatives to develop new routes.

To be able to apply to the scheme a passenger airline operator must have a licence to operate UK domestic air routes.

The scheme is administered by Invest NI on behalf of DfE.

https://www.nibusinessinfo.co.uk/content/coronavirus-ni-domestic-aviation-kickstart-scheme

The Scottish Committee could usefully familiarise themselves with the efforts that the NI Government has been making to protect NI’s current and future connectivity and whether there is a need for a similar targeted intervention to benefit Scottish domestic and international connectivity.

How will airspace modernisation affect Scottish airports? 

No Comment. Such improvements are largely associated with more congested airspace around bigger airports and RABA’s interests is fundamentally in ensuring the interests of airports with less than 3mppa are properly considered.

What schemes are in place to reduce the carbon footprint of airports? 

The SATE Project - The Sustainable Aviation Test Environment (SATE) is part funded by UK Research and Innovation (UKRI) through the Industrial Strategy Challenge Fund[5]. 

The SATE project aims to create the UK's first operationally based, low-carbon aviation test centre at Kirkwall Airport in the Orkney Islands in Scotland and to help decarbonise the aviation industry.

The SATE project features:

• Flight trials demonstrated in a real-life context.
• Trials including low-carbon aircraft using electric, hydrogen and Sustainable Aviation Fuels (SAF) as well as Unmanned Autonomous Vehicles (UAV).  
• Airport infrastructure improvements
• Improved regional air connections
• Local supply chain and employment impacts.
• Contribute to Net-Zero aviation goal by 2040.
• HIAL is Lead partner with a host of other partners.

The project is based at Kirkwall Airport, a busy multi-use operational airfield. Activities include scheduled inter-island and island-mainline flights as well as helicopter operations and international traffic ( 2019 – 190,000 pax and over c.14,500 movements).

A set of industrial and community-based use cases in the ‘real world’ for alternatively fuelled and alternatively piloted aircraft have been developed.

• Inter-island services
• Island-mainland services
• UAV operations and feasibility
• Mail, Healthcare, Oil & Gas etc.

Implementation of these cases will require advances in technology, legislation, regulation and policy.

The project stimulates “road-mapping” reports – technology, certification etc to exploit future flight offers to regional communities; contributes to decarbonising aviation, lower cost operations, new applications; and develops a test environment – physical, digital and operational airport infrastructure is necessary.  The initial project is 18 months long with a series of planned workstreams.

The SATE project features:

• Flight trials demonstrated in a real-life context.
• Trials including low-carbon aircraft using electric, hydrogen and Sustainable Aviation Fuels (SAF) as well as Unmanned Autonomous Vehicles (UAV).  
• Airport infrastructure improvements
• Improved regional air connections
• Local supply chain and employment impacts.
• Contribute to Net-Zero aviation goal by 2040.

A set of industrial and community-based use cases in the ‘real world’ industrial and community-based use cases in the ‘real world’ have been developed.

Inter-island services

Island-mainland services

UAV operations and feasibility

Mail, Healthcare, Oil & Gas etc.

The RABA Group also wishes to draw the Committee’s attention to a range of insights that do run counter to some of the conventional wisdom and heat surrounding the topic of domestic aviation emissions.

Different Types of Aviation have Very Different Current and Prospective Carbon Footprints

In 2018, aviation comprised 7% of UK GHG emissions; this is a far smaller amount than is often referred to, which is usually what aviation is projected to be responsible for in 2050 (i.e. 25%) making no allowance for the introduction of new technologies and operational strategies that could decarbonise it materially over the next 30 years. Indeed, recent DfT figures suggest that UK Aviation emissions have increased 18% since 2000 but have been more than offset by CO2 efficiency improvements averaging 2.2% per year. And earlier this month, all the leading international aviation bodies (i.e. ICAO in the UN, IATA and ACI) have committed themselves to a 2050 Net Zero carbon target by 2050.

DFT Aviation Decarbonisation Briefing - March 2021

Our overriding point is that the industry’s prospective carbon footprint is therefore very often misrepresented in discussions about Climate Change policy; and this applies even more so in Scotland.

So, for example, UK domestic aviation emissions grew only 0.3% between 1990 and 2018, and given 2.2%pa annual reductions in emissions over this period, the carbon footprint of domestic flying has dramatically reduced over the 30 year period leading up to COVID, and it has reduced even more dramatically during the pandemic. Domestic aviation across the UK as a whole totalled only 1.5Mt (3.9% of the total) against UK international aviation emissions which were 96.1% of the total (or 36.7Mt). In other words, the vast majority of UK aviation CO2 emissions are associated with international not domestic flights. This is important in the context of Scotland because, the percentage of air journeys from and to Scottish airports that are domestic rather than international is much higher than in other parts of the UK, with the possible exception of NI, Cornwall and the Crown dependencies.

Scotland’s aviation- based carbon footprint is, therefore, far smaller than other regions of the UK and should not be swept up in generalisations about CO2 targets and policy for aviation at a UK level, especially when distance and travel time makes it a more important mode of transport to maintain Scotland’s competitive connectivity.

This message is strongly reinforced by the graphic above from a recent Eurocontrol Report (below) which shows that the domestic and short haul international flights that dominate Scotland’s air market, are responsible for only a very small percentage of overall European aviation emissions, whilst making up between 24-70% of departures, depending on the sector length chosen. This picture is confirmed by a further study by Deloittes[6] published earlier in 2021 leading to the clear conclusion that domestic aviation (which makes up much of the traffic from the UK’s regional airports) is both currently and prospectively a relatively low emitter of CO2.

This distinction, which many environmental NGOs overlook reflects the fact various categories of aviation play very different roles in relation to carbon emissions, and that geographical differences across the UK are very substantial. Infact, the real culprit, facing the biggest challenge, is long haul aviation.  Whilst RABA Group fully recognises that aviation faces a series of environmental challenges, the largest of which is its carbon footprint, if it is to retain a ‘social license’ to grow, in our view that challenge is heavily weighted towards long haul airlines and therefore the larger airports, which they predominantly serve.

Indeed, as the CCC estimates[7], UK aviation emissions associated with domestic and military aviation fell 11% between 2019 to 2019, at the same time as international aviation emissions increased 1.7%, causing a 0.9% increase on 2018 levels overall and with Covid and the likely return to 2018/19 levels of activity not expected until 2024 and beyond, it will be fully 35 years since domestic aviation emissions have not grown. This is hardly the existential threat that aviation as sector is charged with.  Conflating the challenges facing longer haul aviation is not helpful when considering domestic aviation.

But these facts are rarely if ever rehearsed in the new media who pursue a relentlessly anti-aviation agenda, despite its critical economic and social value to geographically more remote countries like Scotland. Furthermore, nor is it noted that domestic aviation is the most likely to benefit from various technical improvements such as electrification / hybrid; SAF and turbo prop aircraft (route case studies below) in ways that will be more challenging for long haul aviation.  Short haul (near Europe) aviation represents something of an intermediate class between domestic and long haul.

RABA Group Multimodal Carbon Assessments

The UK Regional and Business Airports Group has developed clear evidence that most domestic flying within the UK and Common Travel Area does not result in a per passenger or per passenger/km carbon emissions greater than alternative surface modes other than on thick routes between major cities with modern electric rolling stock – and most UK and N. Irish regional connectivity is not of this nature, because of the limited reach of the HSR infrastructure currently available.

The model, its methodology and a critique of existing widely utilised indices is provided in Appendix 1, with some examples of comparison on specific domestic routes in Appendix 2.

Measurements of emissions needs to be as accurate and granulated as possible to both provide feedback for industry players in their efforts to prioritise efforts and assess cost benefit in their initiatives, and to inform consumers on their choices.  We would contend that current measures, and popular conceptions (and misconceptions), are not accurate enough to facilitate rational progress.

Whole of Life Transport Infrastructure Costs and Emissions

It should be noted that neither the DEFRA (or indeed our own modelling) takes into account whole life emissions from the construction and maintenance of associated infrastructure. For aviation these are very small (runway and aircraft); for other modes (roads/cars, rail network/trains) the ‘life cycle’ carbon footprint will be substantially higher. Academic studies suggest that this factor could double the per passenger kilometre emissions of cars and trains. 

More specifically our regional airport network does not have a capacity problem and any enhancements in usage can be achieved with little capital outlay.  Alternatively, rail upgrades present a considerable burden on the public purse, and will be resisted fiercely by environmental and local lobbying groups.

For example Professor Mäntynen estimates collectively the runways in Finland in commercial use amount to a total of about 70 kilometres.   By comparison the railway network covers 6,000 kms of track and the road network of about 80,000 kms.  He concluded the economic benefits makes the investment to output ratio of airports look extremely attractive relative to other transport infrastructure in Finland. 

Reservations about the 2017 DfT Passenger forecast model

There are reservations within RABA Group about the 2017 DfT passenger forecast mode, and its use in much subsequent discussion regarding the national debate on aviation emissions.  This is laid out in some detail in an Appendix 3.

Radiative Forcing

An area of great uncertainty that is not fully reflected in DfT overviews[8] is the effect of non- CO2 emissions on the overall climate warming effect.  Most studies have placed the so-called radiative forcing effects of these emissions at an RF Index (RFI) of 1.9-2.0.  DEFRA-based calculators automatically include RF on all routes, apparently ignoring EU Guidance indicating it should not be included for flights with sector lengths of less than 500 miles of flight levels below 9,000m (most UK domestic flights).  The MCAM[9] model eliminates such inaccuracies (which homogenize emissions from long haul and short haul flights) using the following well sourced table:

Sourced from EcoPassenger Environmental Methodology and Data Update 2016[10]

The following graphic from the BBC represents a common view of regional aviation, which it should be noted includes radiative forcing (see above), which is structurally wrong, as unlike some of our own analysis (see Appendix 1+2), it relies on DEFRA conversion factors rather than route specific characteristics and rolling stock.  This, in our view, presents a very distorted picture.

Fly Local

In relation to environmental considerations we would like to highlight one under-emphasised aspect of travel’s environmental impact, and that is the terrestrial journey to catch the necessary flight.  We for instance support the benefits of ‘FlyLocal’ to reduce this impact and increase the utility and user benefits of aviation for socio-economic purposes.  Various of our member airports have been considering this issue, and even attempting to quantify the extent that leakage from a catchment to another catchment imposes avoidable environmental burden.

To put these figures into some kind of perspective consider the CO2 impact of the 1,189,357 passengers from South Wales that in 2019 were estimated to have used Bristol airport to fly.   Using Cardiff City Centre as an ‘averaged’ start point and occupancy at 1.44 per average[11] vehicle results in a total estimate of 80,132,928 extra miles travelled, which generates 24,000 tonnes of emissions (mostly by car).  It is estimated that 4 trees absorbs[12] approximately 1 tonne of CO2 in above ground biomass over a period of 100 years (estimate from Trees for Life).  If we look at the mileage generated by Welsh traffic leaking to Bristol - one acre of rainforest stores the same amount of CO2 emitted by driving a car 800,000 miles (Ovo Energy).  So the 80 million driven miles associated with Wales’ leaking traffic is the equivalent to losing 80,132,928 divided by the 800,000 acres of rainforest, or 100 acres of rainforest each year. 

In considering the leakage to Dublin Airport from the City of Derry Airport (CODA) Catchment it was noted for the purposes of that exercise to have considered both higher and lower estimates of the numbers travelling to Dublin by terrestrial means in restored pre-Covid times.  More accurate survey data would be required to firm up the actual numbers.

Based upon conversations with CODA Airport management and considering Dublin Airport’s reports on modal access compiled for other purposes, the following estimates on modal access breakdown in accessing Dublin Airport from the Northern Irish northwest were made. 

These were then used as the basis for calculating the emissions associated with these leaked journeys   compared with if the passengers concerned had used CODA.  The results are shown in the table overleaf.

CO2 from Passengers, within CODA Catchment, Travelling to Dublin by Ground Transport to Catch Flights (kilos of Co2)

In any assessment of the benefits and disbenefits of establishing an air service between CODA and Dublin Airport a consideration of the environmental impacts of a ‘do nothing’ scenario should be considered (above).  The environmental cost of accessing the Belfast Airports from CODA’s catchment will be considerably less on a per person basis, but the numbers making the journey are inevitably much greater.  More work would need undertaken to quantify this.    In Appendix 4 we also provide some evidence of the counter-factual when a key service does not exist how the catchment leakage can become very pronounced.  The example is from Inverness during the 2009-2013 period when it had no direct link to Heathrow; thankfully now rectified, but counter-factually illustrating what will happen if regional aviation retreats.

Airfreight Considerations

Air freight is sometimes misunderstood in terms of its comparative carbon footprint in relation to:-

(a) other modes.  Air freight consignments should be flown from closer to origin and destination.  It is more flexible than rail or shipping and no good analysis has been done of road freight vs air freight emissions per tonne. Nor has the footprint of building/maintaining infrastructure for road/rail freight been properly factored in, say for example vis a vis SAF aircraft. 

(b) life cycle emissions of freighted products. Key air freighted perishables need to considered on basis of carbon footprint to grow them in the right natural environment versus the footprint of building greenhouses and heating them, as well as negative impact on welfare of originating states through local substitution.

Business Aviation

Business Aviation, we point out, is a good target for trialling and pioneering Sustainable Aviation Fuel (SAF), as it is more affordable in terms business jet economics.  Perhaps government could create incentives (such as tax) to speed and facilitate the transition in that economically important sector.  One of our business aviation airports for instance is already currently offering SAF fuel with a 35% blend, which is much higher than contemporary aviation-wide offerings.

Emerging Technologies

We contend that domestic connectivity can be, in large measure, achieved more cheaply and with less environmental impact by air – particularly between those far flung and less densely populated parts of the UK.

In the likely timespan of many of the road and rail upgrades that may be considered the first part of aviation to largely decarbonise will be domestic, shorthaul and smaller aircraft movements, which should be largely electric within a 15 year timespan. 

E-VOTL and battery aviation will be maturing at pace, and is likely to also be much quieter.  It should be noted that the radiative forcing multiplier, which is applied to higher level aircraft flights, will not now, and increasingly in the future, apply to small, lower flying and electric aircraft vehicles.

These new technologies may well have a material effect on comparative transport assessments particularly for short haul and domestic aviation, and change the economics of thin route flying.

Recommendation: RABA Group urges the Committee to insist on accurate data on emissions to better guide evaluation of progress and to ensure accurate cost benefit in spending. None of this will work optimally if government does not have accurate comparative information on current emissions and good forecasts - and currently the Government arguably has neither.

Appendix 1 - The Multi-Modal Carbon Assessment Model (MCAM)

This model was initially developed to support the UK Regional and Business Airports Group.  It was developed to explore, more specifically and accurately, the carbon comparisons on the routes of interest to the group, which are overwhelmingly domestic routes).  It was considered valuable to compare the carbon footprint of alternative modes, alongside cost, time, reliability and economic value of undertaking a journey by different modes.

The developers of the model noted how most existing models use generic and averaged data to calculate carbon emissions for a specific individual’s journey, some of which may bear no resemblance to the routes from which the data is sourced.  When this ‘blended’ data is used and quoted without appropriate caveats, it is potentially both inaccurate and misleading.

There is therefore evidence of serious oversights in methodologies which leads to aviation, particularly on domestic routes being presented in an unfair light.  The MCAM model is designed to address this and bring clarity and accuracy to such modal assessments.

MCAM currently compares the use of aircraft against train, ferry and car travel with additional functionality to cover coaches recently added.  MCAM can calculate comparative multi-modal outputs on a single O&D journey or emissions by individual modes for multiple journeys.   It generates total CO2 emissions per trip by mode thereby allowing the cost of offsetting the carbon emitted on a per person and per pax/KM basis.

User inputs require specific vehicles for the journey (e.g. aircraft type or train class).  This enables MCAM to calculate emissions on a defined journey with greater accuracy than generic bi-modal calculators.  Automation allowing multi-modal and multi-leg journeys is possible to develop, but is currently assessed by segmenting the overall journey into distinct stages by mode.

Existing rail calculator models for instance assumes diesel and electric trains produce the same emissions when in reality they are very different with various Power Units and train sets.  They ignore the limited extent of the electrified network in the UK.  In the UK cross country and peripheral diesel train still predominate.  They assume blanket load factors across the entire UK rail network, ignoring variations between commuter, inter city, cross country and remote routes, and rural and urban journey components. The Government methodology (as used by DEFRA) takes average load factors across the entire UK rail network and so does not account for time and route variances in load factor.  The assumption that suburban/regional train and intercity train can be put together under one category (national rail) with no differences is very approximate and produces misleading outputs.

A stopping train is also assumed to have the same emissions as a limited stop, High Speed or Semi-Fast Express train, when significant energy is actually expended stopping and starting heavy trains.

Mileage of rail journey is assumed the same as car journey, when train frequently takes significantly different routes.  No allowance is usually made for the significant life cycle emissions associated with building and maintaining a large rail network.

Similar issues are associated with the assessment of ferries.  DEFRA conversion factors are based upon generalised, combined totals of passenger km. and fuel consumption.  They use distance-based methods, not taking account of maneuvering nor delays (likely with volatile seas). They produce one figure for each type of passenger aboard a ferry ignoring that nearly every ferry has different designs and emissions.

Online calculators have similar associated issues in relation to aviation.  They do not generally calculate emissions associated with different aircraft, their specific routings and sector length.  They do not account for taxi time (e.g. at congested or uncongested airports), and variations in length climb-out length, cruise and descend phases on specific sectors.   The DEFRA approach provides fixed conversions based on sector length for a limited number of aircraft types, introducing inaccuracies.  For instance turboprops which are very popular in domestic aviation are more fuel efficient than jet engine aircraft.

DEFRA-based calculators also include Radiative Forcing ignoring EU Guidance indicating it should not be included for flights with sector lengths of less that 500 miles of flight levels below 9,000m.  In summary MCAM makes more realistic assumptions about region-specific rail and car-based load factors, and can explore various load factor assumptions on specific air routes.

Appendix 2 - Some Domestic Route Emissions Modal Comparisons

Appendix 3 - Reservations about the 2017 DfT Passenger forecast model

In late 2017 Deb Barber (previous CEO at CWL) alerted the UK Regional and Business Airports Group to the recently updated UK air traffic forecasts that DfT published on 24th October in conjunction with their renewed consultation on the National Policy Statement. Deb’s view, which we completely agree with, is that the new forecasts (which are buried in a table on page 137) are both alarming and because of their provenance potentially very damaging to the Welsh Government’s interests. 

The table in question details passenger demand projections for all the main UK airports; and amongst this data are some very constrained forecasts for Cardiff, which are completely out of kilter with the airport’s own forecasts.  The forecasts shows CWL pax numbers falling from 1.4m today to 0.8m in 2030, before rising to 1.1m in 2040 and 3.0m only in 2050 (central forecasts).

Our view is that the model is not suitable for forecasting small airports, and should not be used for that purpose without appropriate interventions.  It seems that DfT have grouped all airports under 5 mppa in one block called ‘other airports’, or simply generated the forecasts at a regional level, perhaps with the larger airports (for which the model is much better suited) shown separately. Although there are some shortcomings in the macro-element of the modelling suite (e.g. the carbon prices assumed are unrealistically high, the level of bio-fuel use too low and the market maturity rates used too low for a post Brexit Britain trading more extensively beyond Europe), it is the way in which the SPASM multinomial allocation model has been used that appears to be the route of the problem for small airports. Our analysis for Debs at that time might be of interest to you as you develop your JetZero plan.

SPASM works by growing existing patterns of demand across a complex matrix of cells at different rates reflecting sectoral CAGR’s and elasticities from NAPAM, influenced by changes in surface accessibility, service frequency/aircraft size, airport capacity and shadow pricing associated with demand being spilt from congested airports in the South East outwards to other airports across the country.

Hence if you do not have trips in the baseline model cells (each cell is an airport, destination and type of traffic), when the additional demand from the first model is added into SPASM, it will be multiplied by zero in those cells.  So whereas Heathrow, which has lots of trips in every cell, to be multiplied by the new demand, a small airport will not in most of them. The result is the big airports get bigger, the small ones stay the same or in some cases get smaller as improved frequency at nearby airports or better surface access times to bigger airports increase their catchment and hence market share of the new demand in the baseline cells.  One has to intervene to override this core structural bias in the model, by 'seeding' demand to reflect the inherent preference for passengers to use their local airports, not to bypass them to go to a larger airport a long way away, but to do that requires an in-depth understanding of route development and a facility with behavioural (rather than traditional neoclassical) economics that the DfT do not have. 

SPASM (the allocation model) has been built on neo-classical principles, although it does not model a fundamental parameter for such a model, namely price (e.g. fares and airport charges), just values of time.   As such it is becoming dated and needs to be redesigned to reflect behavioural economic theory based on a better understanding on the behavioural choices of the key players in the sector (i.e. passengers, airlines and airports) and how this would mean demand would be allocated within a capacity framework largely determined by Government.

What DfT really ought to do is build a "trip" based model which looks at how predicted changes in the key factors which determine changes in demand (e.g. population, GDP/head, economic sector mix and growth, visitor numbers, surface access links/alternatives, fares, elasticities) at a local level are then affected by behavioural choices (highlighted using revealed preference techniques) within single and over-lapping catchments, would play out in the context of the overlying macro-level growth in different traffic which the DfT's macro-work projects.  The reason they don’t is that this would be complicated to integrate because such models will work better at a regional scale – (e.g. Wales, Scotland, North of England), and that would require DfT to have sufficient market knowledge to be able to balance regional outputs to national macro-demand forecasts.  And that is where DfT are weakest.

The importance of what at first may seem an arcane technical issue, is that DfT’s forecasts are frequently used (or referenced) in land use planning, transport and investment decisions and a systematic under-estimating of regional aviation activity has a dampening effect on surface access, economic and other projects and policy initiatives in the regions.

We believe there is a strong case for re-configuring the structure and process for generating these forecasts, by moving to a series of regional airport systems (e.g. Wales/South West, Scotland, NI/RoI, North of England, Midlands and London and the South East) using different modelling techniques, which then need to be reconciled against the DfT’s overall macro figures. Not only is this likely to ensure regional airports are seen on their own merits, rather than as satellites or spill locations for traffic the South East cannot handle, but it would also give regional transport agencies access to their own forecasting capacity with which to challenge centralised DfT projections for example when assessing changes to APD, defending allegations of anti-competitive behaviour, under-pinning long term masterplanning, evaluating economic benefits from enhance connectivity, making the case for investment in airport capacity and surface access and securing airport re-financing.

In light of criticism from RABA Group and many other parties the DfT issued a clarificatory note[13] regarding the model.

Appendix 4 - Catchment Leakage Counter-Factual

In 2012 when Inverness did not have access to Heathrow the local transport partnership (HITRANS) was advocating for some sort of intervention to address this.  HITRANS’ work on an Update to the 2012 Evidence Note and  its 2012 predecessor report provided compelling evidence of the importance of airlinks from Inverness to main London Airports.  The report highlighted the extent of catchment leakage from the Highlands largely because of lack of access to London Heathrow.  For the purposes of this consultation this data provides something of a counterfactual, if large terrestrial access to airports are baked into the UK’s transport strategy.  We quote from page 4 of that report.

Despite its relative isolation there is still a substantial leakage of traffic from Inverness’s core catchment in the Highlands and Moray.  Since the 2009 CAA survey this seems to have grown materially from around 320,000 in total to nearly 500,000 in 2013.  At 44% (vs 42% in 2009) this is well above the levels at many regional airports.  Of those leaking passengers that are London bound, the percentage flying to LHR increased from 62% - 77% in the period between surveys.  In other words it has become the principal London airport which passengers in Inverness’ catchment area are willing to travel to another airport to access.  Heathrow’s dominance in this regard is function of the onward connectivity it offers and seems to have increased in absolute terms between surveys, despite 12,000 connecting passengers now using the new Amsterdam route.

Presented diagrammatically the situation was as follows.

Source: CAA Scottish Airports 2013 Survey Data

It should be noted that most of this leakage will have been accomplished by car because of deficiencies in the frequency and utility of rail and coach alternatives.

October 2021