Representation by Aviation Environment Federation (Aviation Environment Federation)
- Date submitted
- 28 October 2023
- Submitted by
- Non-statutory organisations
AEF opposes this application for a Development Consent Order (DCO) on the basis that it is likely to generate a significant increase in greenhouse gas emissions, and other climate impacts, that runs counter to the UK’s net zero obligations. There is a high risk that the carbon dioxide (CO2) emissions reductions from aircraft, relied upon by Gatwick Airport Limited (GAL) in its forecasts, will not be achieved. If the airport feels confident that in fact the emissions increases will be aligned with Government’s policies and measures then it should agree to a binding set of annual emissions caps in line - at least - with the Government’s proposed CO2 trajectory for aviation. The Aviation Environment Federation (AEF) is a national non-governmental organisation that campaigns on aviation’s impacts, for people and the environment. The organisation was set up in the 1970s to advocate for more effective policy for people affected by aircraft noise, and we continue to represent the interests of our members in relation to local airport impacts. We are also very much engaged in policy addressing aviation and climate change. We hold the only ‘civil society’ seat on the Government’s Jet Zero Council; we’ve given evidence to parliamentary committees on airport expansion and climate change; and we sit on the advisory board to the industry coalition Sustainable Aviation and Airport Council International’s Airport Carbon Accreditation Scheme. At the international level, we are a formal Observer at the UN’s International Civil Aviation Organisation (ICAO) where we represent a global coalition of NGOs and participate actively in ICAO’s environmental work programme including the ongoing development of its offsetting scheme, CORSIA. AEF has eight member groups concerned about the impacts of Gatwick Airport and opposed to its expansion. While our focus as an organisation is on policy, we recognise that it is not the role of the Planning Inspectorate to change or to challenge Government policy. Our comments here therefore focus on those areas in which the Planning Authority does have an important role. All statements of Government support for airport expansion are qualified with wording about justification and sustainability to be judged by the relevant planning authority. There is nowhere in Government policy that states that climate considerations should be excluded or given zero weight in the planning process for airport expansion. Instead, the Government establishes a clear test that the expansion of any airport must meet its climate change obligations. We therefore highlight here what we consider to be relevant evidence on the climate impact of this proposal to be taken into account in the planning decision-making process. We further argue that if the scheme is given approval, it must come with enforceable conditions that greenhouse gas emissions will be capped, at least in line with the emissions forecast presented by the Applicant. This proposal would generate a larger increase in both passengers and emissions than any airport expansion proposal since the passing of net zero legislation in the UK, so the issue requires some close attention. The Applicant is wrong to rely on the efficacy of current policy measures to reduce emissions to net zero by 2050. The emissions forecast from the Applicant has been based on the Government’s ‘High Ambition’ trajectory for aviation in the Jet Zero Strategy. This includes modelling assumptions – on alternative fuels and more efficient aircraft – that are significantly more optimistic than earlier forecasts. Anticipated emissions associated with the project are therefore much lower than previously expected: using the Government’s pre-Jet Zero assumptions, the increase in emissions associated with this project would have been in the region of 1MtCO2 in 2050; the adoption of the Jet Zero assumptions sees this number fall to 0.513MtCO2 in 2050. This highlights the sensitivity of the forecasts to the assumptions regarding proposed mitigation. The Applicant claims that “Jet Zero commits the UK Government to implementing measures to fulfil its legal duty on net zero, and to management of emissions from aviation within this.” In fact, however, while the Jet Zero Strategy set out the Government’s targets and aspirations for emissions reduction, many of the measures that would be required to achieve this are uncertain and some are beyond the Government’s control. The rate of commercialisation of more efficient aircraft, for example, is not typically a matter for national governments and the Jet Zero Strategy makes no policy proposals on this topic. Similarly, the strategy makes optimistic assumptions about global carbon markets but beyond advocating for global policy change, the UK has no power to ensure that the CORSIA scheme does in fact become more rigorous after it ends in 2035, and the strategy does not propose any backstop policies if the plan to rely on the international carbon market is not successful. While the UK ETS, applicable to domestic and international departures to EEA destinations, offers a more robust scheme that the Government intends to align with net zero, its international route coverage is also subject to CORSIA rules and the Government is still “carefully considering the approach to [this] interaction”. On uptake of Sustainable Aviation Fuel (SAF), while the Government has begun to develop proposals for a SAF mandate, big questions remain to be addressed about issues such as feedstock sourcing, and proposals to develop a UK SAF industry, beginning with the construction of five SAF plants by 2025, already look off track. The Climate Change Committee’s most recent Progress Report characterised the approach of the Jet Zero Strategy as “high risk due to its reliance on nascent technology” (echoing a similar conclusion from Element Energy, in a report commissioned by AEF http://aef.org.uk/uploads/2022/05/The-Role-of-Aviation-Demand-in-Decarbonisation-Full-Report.pdf ). The CCC report argues that the expansion of airports permitted by the Government in recent years is “incompatible with the UK’s Net Zero target unless aviation's carbon-intensity is outperforming the Government's pathway and can accommodate this additional demand” and that “No airport expansions should proceed until a UK-wide capacity management framework is in place to annually assess and, if required, control sector CO2 emissions and non-CO2 effects.” We recognise that the Government has the right to reject the CCC’s advice and has recently published its response. As noted by the Applicant, however, the Secretary of State ultimately has responsibility for ensuring that climate change legislation is adhered to. The application states: "An important element of Jet Zero is that the emissions trajectory for the aviation sector will be monitored on an annual basis whilst the Strategy itself will be reviewed every five years. This acknowledges that decarbonisation will rely on new technologies which require time to develop and test. However, the Strategy explains (for example, on page 10) that the Government will intervene with new measures if the sector is not meeting its emissions trajectory." It would seem to us that if the CCC is correct about the Government’s strategy being unrealistic in its reliance on new fuels and technologies coming rapidly to the market, and if its modelling for airport expansion is therefore inappropriate, then the Government will in the near future need to act to rein in emissions by way of demand reduction. This should – at least – be recognised as a risk to the financial case being made for expansion at Gatwick (and at other airports). The downward revision of the level of demand forecasted by the Government from 70% to 50% within the space of a year (between the publication of the Jet Zero Strategy and of Jet Zero: One Year On) illustrates how vulnerable these estimates are to change. The Government’s climate change obligations are not confined to 2050: the Sixth Carbon Budget (2033-37) and the Government’s interim target of a 78% reduction in emissions below 1990 levels by 2035 are also notable milestones. The emissions associated with this project during the 2030s should be examined closely given that GAL forecasts a higher trajectory for emissions in this decade (and for its cumulative emissions generally out to 2050) compared to the Government’s Jet Zero strategy (see Diagram 16.9.3 in TR020005). The Applicant should have modelled the non-CO2 impacts of the proposal. There is a longstanding policy gap related to the non-CO2 climate warming impact of flying. The CCC states in its sixth carbon budget advice (box 8.6) “non-CO2 effects contribute around two-thirds of the total aviation effective radiative forcing – twice as much as historical CO2 emissions from aviation.” The Applicant argues, however, that: "[Given] that there remains no well-established methodology for quantifying non-CO2 emissions impacts, and there is uncertainty on how to identify the magnitude of their impact, this assessment does not attempt to quantify non-GHG and RF effects of emissions at altitude. Providing a comparative set of figures alongside the CO2 emissions would be incompatible with an assessment against national CO2 targets, and as noted above, the generalised approach to providing CO2 equivalent estimates to reflect the combined impact of different GHGs is not transferrable to non-CO2 emissions." We don’t agree with the decision not to provide an appraisal of the non-CO2 impacts of the proposal. While it is true that uncertainties remain about the correct methodology for quantification of these effects for the purposes of policy, failure to provide any estimate is not an adequate response. While we await policy proposals for tackling aviation’s non-CO2 impacts (the Government, working with the Jet Zero Council, has launched a work programme on this issue), it would improve the transparency of the proposal for an estimate of non-CO2 impacts to be provided, for example using the approach recommended by the Government for company reporting of travel emissions (which is to apply a multiplication factor of 0.7 to the CO2 impact to account for non-CO2) in order for the inspectors to weigh this additional harm in the balance. It should also be noted that the European Commission is consulting on the objectives, scope and first steps for establishing a monitoring, reporting and verification system for non-CO2 effects in aviation as part of the EU Emissions Trading Scheme (ETS), while the UK Government recently consulted on how non-CO2 impacts could potentially be included in the UK ETS in the future. The Applicant should have made a commitment to cap aviation emissions as part of its Climate Action Plan As set out above, our view is that a significant airport expansion such as the proposal at Gatwick should not be permitted in the absence of much greater certainty about the effectiveness of proposed mitigations for aviation emissions. If, however, the airport has confidence in the Government’s plan – as indicated in its Environmental Statement and as reflected in its use of the Jet Zero modelling assumptions – then the Applicant should agree to the imposition by the planning authority of an enforceable annual cap on aviation emissions associated with the airport. The Applicant states. In relation to its Carbon Action Plan or CAP: "Our commitment to play our part in the UK's Jet Zero trajectory is not contingent on the Project being consented, but the CAP uses the legally binding nature of the DCO application to provide an additional level of assurance to stakeholders." However, aircraft emissions are essentially excluded from the Plan. While the airport may argue that these emissions are beyond its direct control, the same could surely be said of aircraft noise, which is nevertheless frequently subject to planning conditions and limits on capacity. We note that despite adopting the Jet Zero modelling assumptions, Gatwick anticipates its own emissions trajectory being very different from the national trajectory – increasing from current emissions levels and then flattening out but not falling nearly as steeply as the average across all airports (Diagram 16.9.3 in TR020005). We would suggest that - as a minimum – it should be required by way of conditions that the Applicant’s forecast level of emissions must not be exceeded in any year. A more stringent set of annual caps could also be considered. The Jet Zero Strategy still allows for a high level (nearly 20 Mt) of emissions to be generated by the sector even by 2050, with ‘out of sector’ carbon removals assumed to be in place to balance these emissions. Arguably the curve towards zero should be much steeper. The setting of an emissions condition would help to provide accountability for the claims and assumptions being made. While this approach would be new, and would require some additional work to be done in terms of developing the appropriate wording for a planning condition, we see a strong case for introducing one if the scheme should go ahead given the importance of the climate change issue and the current lack of enforceability of hoped-for emissions reductions.