Department for Transport – Decarbonising Transport, setting the challenge

A member of TAG has responded to the DfT consultation paper on decarbonising transport. This is an important topic since transport accounts for 35.7% of the total UK carbon emissions. Taking the DfT’s own figures, of the transport share of CO2 emissions, aviation takes up 29% of that share (aviation taking 37 MtCO2 out of a total transport emission amount of 124 MtCO2 in 2018). Far from the small 1% contributor that some would have us believe, aviation is a very substantial contributor to CO2 emissions and therefore climate change.

It is our view that aviation cannot be expanded to anything like the extent that had been proposed prior to the Covid-19 lockdown. Below, our member responds to the DfT and explains our reasoning, commenting on the chapters of the DfT’s paper, which can be accessed by clicking on the icon at the side.

Below is a section of the submission dealing with aviation. The submission does not take into account the effects of the Lockdown:

Chapter 1. Greenhouse Gas emissions and transport

It is misleading to say that “Between 1990 and 2018, we reduced our emissions by over 43% while growing the economy by 75%”.

Manufacturing produces greenhouse gases and UK manufacturing output has diminished as a proportion of Gross Domestic Product. According to the January 2020 Parliamentary Briefing Paper entitled “Manufacturing: statistics and policy”:

“Manufacturing’s share of UK economic output (in terms of Gross Value Added) has been in steady decline for many decades, from 27% in 1970 to 10% in 2018”.

In 1990, manufacturing was 17.3% of Gross Value Added “GVA”, while in 2018 it had reduced to 9.9%. That is getting on for a 50% reduction in proportion of manufacturing to GVA in the time that we saw a 43% decline in greenhouse gas emissions: not quite as impressive. The Gross Value Added of manufacturing has declined from 100 points in 2007 to 99 points in 2018 before factoring inflation. The RPI All Items Index for 2007 was 206.6 and for 2018 was 281.6 (an inflation rise over that period of 36%). Therefore the 100 points if inflated by the increase in RPI Index to 2018 would have been 136, showing a true reduction in manufacturing to GVA of 37.3 points. While the economy as a whole might have grown by 75%, this is by inflation and expansion of the service sector, which is a relatively low carbon emitter.

The UK now has a low manufacturing base compared to many other countries. According to the Parliamentary Briefing Paper, the UK at 10% has a lower proportion of manufacturing to GDP than Germany (23%), Japan (21%), Italy (17%), Netherlands (12%) and France (11%).

If we were to look at the carbon gases produced in the global manufacture of items subsequently consumed in the UK, the likelihood is that the UK has not reduced its emissions at all between 1990 and 2018. With something as important as this, it is imperative that we are honest with ourselves. It is no use our crowing about our own greenhouse gas reductions and frowning at countries like China and India increasing theirs, while at the same time exporting our emissions to those countries by exporting our manufacturing to those countries.

The UK might crow about being the “first major economy to pass a net zero law to end its contribution to climate change by 2050”, but we are cheating by discounting a whole lot of our greenhouse gas emissions.

Despite all the technological improvements, we see that CO2 emissions from transport have reduced only slightly between 1990 and 2018 – down from 128 MtCO2 to 124 MtCO2. In 2018 aviation (including our contribution to international aviation through planes departing from UK airports) produced 37 MtCO2, which is 29.8% of the whole UK transport CO2 emissions. That is more than buses, more than HGVs, more than vans, and only very slightly less than HGVs and vans combined. Only some 15% of the population use planes, whereas 100% of the population have some use from delivery by HGVs and vans. More on this below.

To go forward, the first step is to honestly address and recognise the problems, putting aside vested interests. The problems can then be addressed. The truth is that we are all going to have to wean ourselves off, or reduce reliance on, the high pollution forms of transport like aviation and lean towards new low emission technologies

Chapter 2 . Moving people – emissions by mode


As you correctly say, emissions from international aviation have more than doubled since 1990. In the following paragraph you then say that “Aviation, at present, is a relatively small contributor to domestic UK GHG emissions.” That is grossly misleading, since it ignores the international aviation directly derived from UK operations. At 37 MtCO2, aviation makes up 29.8% of all transport greenhouse gases (aviation emissions of 37 MtCO2 ÷ total transport emissions of 124 MtCO2 x 100). You then state that “It is widely agreed among states that a sectoral approach (rather than state-by-state) is preferable, which is why the Kyoto Protocol gave UN International Civil Aviation Organisation (ICAO) and the International Maritime Organisation (IMO) responsibility for pursing measures to reduce these emissions”. Again, that is misleading. It is true that the aviation industry (including the ICAO) wants to retain responsibility for international aviation. But it is widely recognised that this will not achieve the required net zero by 2050[1]. As long ago as 2009, our own Committee on Climate Change has been saying that international aviation must be provided for in planning.

According to your figures produced in chapter 1, the total UK domestic greenhouse gas emissions for 2018 was 451 MtCO2. Add our contribution to international aviation and shipping and that rises to 496 MtCO2. Aviation takes 37 MtCO2 of that, which is 7.45% of the total gross UK CO2 emissions – and that excludes the non-CO2 greenhouse gas emissions from aircraft, so the effect is higher. By 2017, transport was the biggest contributor to UK greenhouse gas emissions in the UK. To exclude a gross contributor to total UK CO2 emissions of 7.45% and rising, as well as a contributor of 29.8% of the transport emissions, is hardly something to be proud of.

In its 2009 publication “Meeting the UK aviation target – options for reducing emissions to 2050” the Committee on Climate Change stated that:

“In our December 2008 report, we set out a preliminary analysis of aviation emissions including emissions projections and scope for emissions reduction through innovation in engine, airframe and fuel technology. We concluded that global aviation emissions could account for a significant proportion of total allowed global emissions in 2050, and we argued that they should therefore be included in climate change strategies and policy frameworks. This would provide incentives for supply and demand side aviation emissions reductions, and ensure that total UK emissions are reduced in line with appropriate targets informed by climate science.”

The Committee then continued:

“The Committee argued, therefore, that it is essential that aviation should be covered by a policy framework which: (i) Ensures aviation faces an appropriate cost of carbon so as to provide an incentive both for supply side abatement and for demand constraint (ii) Ensures that the total level of emissions (i.e. from aviation and other sectors) is reduced in line with appropriate scientific targets.”

We are now 11 years later in a state of climate change emergency and the Department for Transport is still saying that “action at an international level is the Government’s preferred approach for addressing aviation’s international carbon emissions”. Between the CCC 2009 report and now, we have had a reduction in target CO2 emissions to zero rather than 20% of 1990 levels, we have been advised in the strongest terms by the statutory body that emissions from international aviation should be provided for in domestic budgets[2], that statutory body has suggested that a reduction to less than 30 MtCO2 is required for UK international aviation emissions and CORSIA has been introduced by the ICAO.

On page 32 you state that “However, emissions reductions per plane and per passenger km are driven by larger and more efficient planes, and limited uptake of low carbon sustainable aviation fuels”. It is almost certain that emissions reductions will not be driven by larger planes. We see now, and are likely to see in the future, a progressive move away from larger planes with the decommissioning of aircraft like the Airbus A380 to smaller planes more easy to fill and able to travel from point to point rather than large hubs.

It is surprising that you have not commented on the aviation non-CO2 greenhouse gases, which are now considered to double the greenhouse global warming effects from CO2 alone. This, of course makes aviation even more dangerous to the future of humans

It is the height of irresponsibility for a government to legislate for a reduction in emissions to net zero in one breath and then in the next breath allow a major polluter to continue unchecked in the disguise that it is not a major polluter and in any case someone else will take care of it – even more so when it is directly contrary to the advice given by the statutory body appointed to advise the government on climate change.

Chapter 3 Delivering Goods and Services

It is perhaps unfortunate that you have not commented on aviation, as cargo is a significant proportion of aviation activity and therefore a significant source of CO2 emissions. Does the Government have any views on alternatives to air freight, if so what are these, how will emissions be offset, and how will offsets be applied amongst the aviation and industry?

Chapter 4 The Current Trajectory

You say here that “International shipping and aviation emissions must also be reduced, and Government agrees with CCC advice that the primary policy approach to reducing these emissions should be international”. However, that is not their total advice is it? Their advice is that international should be the primary approach. They then go on to say that “This international framing should not prevent the inclusion of IAS [International Aviation & Shipping] emissions in UK carbon targets, as is already the case for other sectors that are covered by international agreements”. The Committee on Climate Change then give specific advice on what should be done:

“•Aviation is likely to be the largest emitting sector in the UK by 2050, even with strong progress on technology and limiting demand. Aviation also has climate warming effects beyond CO2, which it will be important to monitor and consider within future policies.

•Including IAS emissions in UK carbon targets increases confidence that the Government is appropriately prioritising their reduction. That should include pushing for suitably strong international levers, as well as using supplementary UK measures where these do not impact on the competitiveness of the IAS sectors.

•Inclusion of IAS emissions clarifies the requirements for policy development in other sectors (e.g. the scale of deployment needed for options to offset remaining emissions).

•There are no practical barriers to inclusion. Emissions are already estimated and reported to the UN and should be included in UK emissions targets on the same basis. The uncertainty attached to these estimates is no higher than for other sectors covered by carbon budgets.

•Inclusion can be managed through secondary legislation and without any additional costs for achieving net-zero beyond those already agreed by Parliament.

Formal inclusion of IAS emissions would help to guide long-term policy approaches and infrastructure investment decisions.”[3]

The DfT do not seem to be proposing to do any of these things. Why?

[1] The Committee on Climate Change’s advice dated 24th September 2019 states that “Zero-carbon aviation is highly unlikely to be feasible by 2050.”

[2] Letter from Committee on Climate Change to the Secretary of State for Transport dated 24th September 2019 – see below

[3] Letter Committee on Climate Change to Secretary of State for Transport dated 24th September 2019

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