Aviation 2050 Consultation: Suggested Responses

This resource has been produced to help local groups respond to the UK government’s consultation Aviation 2050 — the future of UK aviation.

10 Jun 2019


This document has been produced by Friends of the Earth to help local groups respond to the UK government’s consultation Aviation 2050 — the future of UK aviation, which closes on 20 June 2019. This version of the document includes updates following the publication on 2 May of the Committee on Climate Change (CCC) advice on net zero.

  • It provides suggested answers to 8 questions, focussing only on the climate change impacts of aviation expansion. 
  • Please use this to respond to the consultation as soon as you can. 
  • It’s fine to simply copy and paste the questions and answers and submit them in your local group’s name. 
  • Alternatively, you can use the answers alongside any additional points that you want to make, for example on air and noise pollution or harm to nature of airport expansion proposals in your local area. 
  • The answers are organised in a way that is consistent with the Government’s consultation response form. Each heading is a numbered question in the response document. 
  • You can respond online, or by completing a response form and emailing it to AviationStrategy@dft.gov.uk or posting it to: Aviation Strategy, Department for Transport, 33 Horseferry Road, London, SW1P 4DR. For full details of the consultation visit the DFT website.
  • The numbering in this resource relates to the online response form. The numbering in the downloadable form to respond by email is a little different so make sure to double check you are answering the correct question.


Suggested responses

15. To what extent does the proposed partnership for sustainable growth balance realising the benefits of aviation with addressing environmental and community impacts?

The approach to dealing with aviation emissions is inadequate. It does not sufficiently address the urgency of tackling climate change. The main problem areas are summarised as follows. Responses to subsequent questions give more detail.

The approach:

  • Relies on a very poor international offsetting scheme (CORSIA) which has a weak target that allows gross aviation emissions to grow rather than requiring reductions as is necessary
  • Does not cover all climate warming emissions. It keeps non-CO2 emissions under review, rather than including robust mechanisms to deal with them
  • Does not introduce measures to constrain aviation
  • Allows airport capacity at Heathrow and other airports to increase
  • Does not include measures to encourage alternatives to air travel
  • Does not encourage institutions or individuals to consider the environmental effects of aviation before deciding to fly
  • Relies on future technology improvements, but does not demonstrate their likely contribution


17. Are there any specific ‘triggers’ (e.g. new information, technology development, etc.) that should be taken into account when planning a review?

We believe that triggers should include (but not be limited to):

  • Information on progress with emissions reductions, particularly with regard to advice from the Committee on Climate Change
  • Scientific information, for example on the impacts of non-CO2 emissions on the climate
  • Technology developments
  • Progress with scaling up technologies
  • Information on climate change impacts on the environment, particularly on the understanding of climate tipping points and any need for faster global action. For example, if the tipping point for the Greenland ice sheet is identified to be at a lower level of warming than expected, or if the melting permafrost tipping point is assessed to be earlier than expected. This information should lead to a broader review of total carbon budgets but will be particularly impactful on sectors that cannot switch to renewable electricity.
  • Information on social impacts of climate change and of measures to deal with it


18. How could the policy proposals be improved to maximise their impact and effectiveness in addressing the issues that have been identified?

Comments on proposal 3.83 (“negotiate in ICAO...”) and proposal 3.88 (“continue to lead efforts in ICAO to negotiate for robust, environmentally effective emissions reduction measures...”)

  • We support the UK taking a leading role in agreeing robust and environmentally effective international measures. However, the currently envisaged scheme (CORSIA) is very poor. It has a weak target that allows gross aviation emissions to grow rather than requiring them to decrease as is necessary for the world as a whole. It does not cover domestic aviation, ignores emissions other than CO2, and its rules do not ensure it has an effective offset mechanism (see the response to question 29 for additional evidence)
  • The UK government should formally reject CORSIA. It should also more actively promote an international aviation agreement that: reduces aviation emissions, rules out unsustainable use of biofuels, covers all climate warming emissions, and is consistent with the 1.5°C objective of the Paris Agreement. 

Comment on proposal 3.95: “keep nonCO2 emissions under review and reassess the UK’s policy position as more evidence becomes available”

  • This does not adequately address the urgency of tackling climate change. The policy should include robust mechanisms for dealing with all climate warming emissions, including emissions other than CO2. Such other emissions include, but are not limited to, emissions such as NOx (nitric oxide and nitrogen dioxide) that contribute to global warming indirectly. We accept that there are scientific uncertainties, and that more research is needed.1 However, uncertainty does not justify inaction. UK policy should address non CO2 effects according to the best available scientific understanding consistent with the 1.5°C Paris Agreement objective.

Comment on proposal 3.96: “consider the use of all feasible abatement options...” and proposal 3.97 “use CCC’s reviews...”

  • These proposals are under the heading “Non-CO2 emissions”. Our understanding is that they are nonetheless intended to apply to all climate warming emissions, and the following comments apply for all emissions.
  • We believe that demand management and behavioural change (mentioned in proposal 3.96) should be used in tackling all climate warming emissions. See the response to question 26 for details.
  • The Aviation Strategy should be updated urgently now that the Committee on Climate Change’s net zero advice has been published (May 2019). We welcome that advice, but believe that a more ambitious target is possible and necessary. See the response to question 26 for further details.
  • Regarding technological developments and sustainable fuels (mentioned in proposal 3.96), we believe that the approach must be to “support development of new technology, but don’t rely on it until it’s ready”. New technologies may bring new solutions in future. But planning must rely only on developments in technology and sustainable fuels that are known to be workable at large scale and that will be available when we need them. The Aviation Strategy should be based on this principle, and should state the planning assumptions being made regarding the benefits of new technology. This is particularly so because doubts have been cast on the Department for Transport’s 2017 CO2 forecasts. The “dramatic and poorly substantiated” reduction in CO2 compared to previous forecasts suggests that “the Government is assuming more advanced technology scenarios towards the upper end of what is likely to materialise”.2


19. How should the proposals described be prioritised, based on their importance and urgency?

The scale of reductions to comply with the Paris Agreement requires an urgent policy response, and the scale of the actual and potential impacts of climate change mean that complying with greenhouse gas reduction requirements must be the top priority for aviation policy. In particular, to achieve the Paris 1.5°C objective, reaching an effective international aviation agreement and putting in UK measures before this comes into effect are the highest priority proposals included in the Aviation Strategy document.


23. Are there any options or policy approaches that have not been included in this chapter that should be considered for inclusion in the Aviation Strategy?

We propose the following measures.

Include aviation in Net Zero target: The UK Government should accept the CCC recommendation that international aviation (and shipping) emissions should be part of Net Zero target, and should in future be formally included within the UK carbon budget, and commit the government to developing and supporting the necessary aviation carbon reduction framework that will therefore be required.

Carbon reduction policy framework:  The UK Government should develop, commit to and then implement a carbon reduction policy framework for aviation as an integral part of a wider reduction policy framework for UK transport as a whole. This is what the Aviation Strategy should deliver.

Cap aviation emissions: UK aviation emissions should be capped at their existing levels, and then reduced as quickly as possible towards an ambitious target.

The UK Government should set tougher emissions reduction targets, including for aviation: These must be legally binding and consistent with the Paris objective to limit temperature increase to 1.5°C. Aviation targets must be achieved without the use of offsets, and the focus must be on the aviation sector reducing its own emissions. They must include all climate warming emissions, and must be reviewed / updated from time to time (see response to question 20 for examples of review triggers).

The Committee on Climate Change’s current planning assumption for a 2°C objective is that by 2050 gross UK aviation emissions should be around 2005 levels. In the light of the Paris Agreement and the Special Report of the Intergovernmental Panel on Climate Change (IPCC) in October 2018, they have advised that a more ambitious overall UK target is needed: net zero emissions by 2050. We welcome this, but believe that net zero by 2045 or earlier is possible and necessary.

We are calling for an aviation target that is more stringent than the 22 MtCO2e in the CCC’s ambitious ‘speculative' demand constraint option. This is because that option ignores most non-CO2 emissions (those that are not included within the basket of gases covered by the Paris Agreement).

Our target is to reduce aviation emissions by 2045 (including non-CO2) to a level that is expected to have the same long term (100 years) effect that a reduction to 22 MtCO2e by 2045 would have. The actual numeric emission level(s) should be set according to the best scientific understanding of the warming effects of all emissions (including non-CO2).

Demand management and behavioural change: Proposal 3.96 (bullet 2, “consider the use of all feasible abatement options...”), mentions policies on demand management and behavioural change that may evolve over the long term. These are important elements of an effective approach to dealing with aviation emissions. We believe that such measures should be put in place urgently, and make the following policy proposals:

  • Constrain aviation: We need to reduce emissions from air travel to and from UK airports. With current aviation technology that means fewer flights. This will require measures such as a frequent flier levy, removal of tax breaks on aviation fuel, and limiting numbers of flights at airports. Taxes should be fair and based on the polluter pays principle, for example with higher payments for longer distances
  • Reject airport capacity increases: A number of airports across the UK are seeking to expand. But we need reduced emissions, and as above, with current aviation technology that means fewer flights. We must stop plans to expand airport capacity, and the decision to grant Heathrow permission to build an additional runway must be reversed
  • Ensure fairness in access to (constrained) aviation: A frequent flyer levy would be a step in this direction. Flying shouldn’t become a luxury reserved for the wealthy. Alternative approaches, such as rationing of flying may be worthy of exploration.
  • Encourage alternatives to air travel: We need to develop alternatives to air travel. For example, long distance train travel (which has much lower emissions per passenger mile), and improved wifi and videoconferencing facilities.
  • Encourage institutional responsibility: Businesses and other institutions should be encouraged to limit their use of aviation and to consider the environmental effects before deciding to fly. A requirement for organisations to report on air travel should be considered. Individuals should also be encouraged to use alternatives to flying.


24. Looking ahead to 2050, are there any other long term challenges which need to be addressed?

Post 2050 the UK will need to be net negative emissions as we drawdown GHGs from the atmosphere to return to 1.5 degrees (if it has been exceeded) or indeed aim for a much lower level of GHG in the atmosphere (e.g. the 350ppm CO2 upper limit promoted by leading climate scientists including James Hansen). This means aviation emissions will need as a minimum to be kept low after 2050 (e.g. well below the CCC’s ‘speculative’ demand constraint  level – see response 26) but may need to reach zero emissions by that date or soon after, depending on the UK’s potential and willingness to drawdown GHGs through natural climate solutions or other means. The industry needs to plan and innovate accordingly.


25. Are you aware of any relevant additional evidence that should be taken into account? 

Select 'yes'.


26. Please give a brief summary of the additional evidence that you wish to provide.

  • Effective action on climate change is urgent: “If we do not change course by 2020, we risk missing the point where we can avoid runaway climate change, with disastrous consequences for people and all the natural systems that sustain us.” António Guterres, Secretary-General of the United Nations, 2018. This sense of urgency should be at the heart of UK government policy, including aviation.
  • Aviation’s current goals are inconsistent with the Paris Agreement3: This fact emphasises the need for more ambitious aviation targets.
  • Most air travel is for leisure: In 2016, 72% of passengers to/from UK airports were traveling for leisure.4 In most cases more climate friendly holidays could be taken closer to home. This has implications for demand management.
  • The majority of plane trips are made by relatively few people: UK government statistics in 2014 showed that 70% of plane trips were made by 15% of people.5 This has implications for fairness of access to aviation.
  • Technology developments are not able to keep up with the growth of passenger numbers. Planes are becoming gradually more efficient and will continue to do so, but not at the pace necessary to allow for unconstrained growth in flights and passenger numbers. This means that aviation needs to be constrained.
  • CORSIA offsets: Many CORSIA offsets are likely to be based on the United Nations’ Clean Development Mechanism (CDM). Evidence shows that such offsetting often does not work in practice. In 2016 a report for the European Commission found that only 2% of projects under the CDM had a high likelihood of being effective.6
  • Biofuels: The aviation industry is banking on biofuels as a future fuel.7 This would require industrial scale cultivation of biomass — things like maize, palm oil or woody crops. It would compete for land with food production and nature protection, as well as risk displacement of local communities overseas. Clearance of forests to make way for plantations can itself lead to massive greenhouse gas emissions. Use of waste and newer biofuel production methods might help, but there is currently no sustainable way to produce aviation biofuel at scale. In addition, biofuels do not eliminate all climate warming emissions. For example, reductions in emissions of indirectly acting NOx are small or insignificant.8 The Committee on Climate Change envisages a limited role for biofuels as aviation fuel (up to 10% in 2050).


  • 1. The scale of the uncertainty is illustrated by the very large error bars in Figure 1 of a report by David S. Lee in the Aviation Strategy supporting documents showing ‘Radiative Forcing’, and by the fact that there are difficulties even in identifying a suitable metric for Non-CO2 effects. See "The current state of scientific understanding of the non-CO2 effects of aviation on climate", https://www.gov.uk/government/publications/aviation-2050-the-future-of-uk-aviation-consultation-sustainable-growth-carbon-reports 
  • 2. See AEF response to draft airports NPS (2017): https://www.aef.org.uk/uploads/2017/12/AEF-comments-on-NPS-reconsultation.pdf 
  • 3. See the report “International aviation and the Paris Agreement temperature goals” in the Aviation Strategy supporting documentation at https://www.gov.uk/government/publications/aviation-2050-the-future-of-uk-aviation-consultation-sustainable-growth-carbon-reports
  • 4. UK aviation forecasts 2017 – report page 60. https://www.gov.uk/government/publications/uk-aviation-forecasts-2017
  • 5. This statistic has been verified by Full Fact. https://fullfact.org/economy/do-15-people-take-70-flights/
  • 6. How additional is the Clean Development Mechanism? Pages 10 and 11. https://ec.europa.eu/clima/sites/clima/files/ets/docs/clean_dev_mechanism_en.pdf
  • 7. The IATA Factsheet “Sustainable Aviation Fuels” says: “In the medium term, SAF [Sustainable Aviation Fuels] will be the only energy solution to mitigate the emissions growth of the industry”. The term “Sustainable Aviation Fuels” includes biofuels. https://www.iata.org/pressroom/facts_figures/fact_sheets/Documents/fact-sheet-alternative-fuels.pdf
  • 8. See section 2 of FAA document Swedish Biofuel Performance Evaluation, 2016, https://www.faa.gov/about/office_org/headquarters_offices/apl/research/aircraft_technology/cleen/reports/media/swedish_biofuel_report.pdf . See also sections 2.1 and 2.6 in ‘Impact of Alternative Fuels On Aircraft Engine Emissions’, presented by the International Coordinating Council of Aerospace Industries Associations in 2009. https://www.icao.int/Meetings/caaf2009/Documents/CAAF-09_IP011_en.pdf
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