18th December 2024 In the third article in this series Anthony Rae – author of the Will Labour fail its transport decarbonisation test? report – picks up the story from last week’s ‘transport eats the UK carbon budget’. Is it the case that, in turn, ‘aviation will eat the transport budget’, and if so what should the Climate Change Committee do to prevent this? It’s almost double the length of the previous pieces, so consider it as your Christmas break ‘long read’!
Article #2 – which it’s suggested readers should familiarise themselves with before proceeding further – described how a straightforward analysis of the ‘transport emissions numerator/UK carbon budget denominator’ fraction could be used as a predictive tool – of the extent to which, since the Climate Change Act’s 1990 baseline, transport emissions will continue to take an ever increasing share of the UK carbon budget (UKCB) – and as a diagnostic tool , spotlighting structural failure in the DfT policy frameworks for roads and aviation which are driving that emissions increase .
The assessment of the May 2024 Labour decarbonisation test report, and of developments since the new administration took office in July, is that the Labour government is more likely to keep those policy frameworks in place. (The final article in this series 4th January will review this judgement after the government’s ‘first 6 months’). With total transport emissions (TTE) already at ‘36% and rising’ of the UKCB, the consequence is that it would be almost impossible to decarbonise the UK’s largest emissions sector and achieve critical NDC targets in 2030 (-68% off 1990) and 2035 (-81%). But the report also noted that the TTE pathway was an aggregation of two completely divergent trajectories: one for road requiring radical reductions in emissions as EV transition began, but the other for aviation almost none: just 1MtCO2e between 2023 and 2030. Why was that, and what does it signify?
For those unfamiliar with the aviation analysis, it’s important to recall one other point by way of context: Labour’s track record on aviation policy when it was last in government 1997-2010. As recounted in another Transport North article in August, it was a Labour government which launched the process to prepare for a huge expansion in UK passenger demand, airport capacity and consequently emissions across the next decades. (I cut my teeth as an aviation campaigner participating in the northern regional reference group from 2000 onwards). A Labour government that in 2003 published its Air Transport White Paper, which comprehensively planned that growth programme and resolutely defended it across the 2000s. And which in 2009 then took the decision to support the provision of a third runway at London Heathrow. On the other hand it was the subsequent Conservative/Lib Dem coalition government which immediately countermanded the HR3 process in 2010.
But as we can see in this diagram (download the data note for an enlarged image) the surge in the passenger demand ‘driver’ – which then leads to expanding airports and higher emissions – had been visible to policymakers for the previous decade and was part of the background which the 2003 White Paper should have responded to. Passenger demand since 1990 had doubled from just over 100 to 200 million passengers per annum (mppa), and emissions increased from around 20MtCO2e to approaching 35MtCO2e.
What the Labour Department of Transport deliberately chose to do was turbocharge these trends. The White Paper proposed a huge expansion in passenger demand , to between 400-600mppa in 2030, additional runways and enlarged terminals to facilitate this growth, and thought it quite reasonable to presume that in 2030 aviation on its own would be entitled to take up ‘about a quarter of the UK’s total contribution to global warming’ ATWP 3.35/37. These expansion plans were masked by messaging spin, suggesting the opposite of what was being promoted: ‘The Government believes that simply building more and more capacity to meet demand is not a sustainable way forward.’ Nonetheless ‘reduction in greenhouse gas emissions across the economy does not, however, mean that every sector is expected to follow the same path’. That is, not the aviation sector.
Yet it was also the same Labour government that in November 2008, and with huge cross-party support, passed the Climate Change Act. One of the Climate Change Committee’s first tasks was to make a detailed examination of the aviation emissions problem in their December 2009 report Meeting the UK aviation target – options for reducing emissions to 2050. But what I noted at the time was that the ‘UK aviation target’, which you might think CCC was meant to be independently assessing, had in fact already been determined in advance by the Labour government. The CCC report states: ‘In January 2009, the Government decided both to expand Heathrow airport, and to set a target that UK aviation emissions of CO2 in 2050 should not exceed 2005 levels. The Committee was asked to advise on options for reducing emissions below business as usual to meet the target and on the implications for aviation expansion in the 2020s.’ It was this target – a CO2 emissions limit of 37.5Mt – arbitrarily selected and unrelated to the climate science, that was consequently embedded in the CCC recommended carbon budgets 1-5 all the way to 2032. In fact, the Parliamentary statement announcing the target demonstrates it was suggested by the aviation industry itself Hansard 15th January 2009 column 359.
For its first decade therefore the CCC’s aviation analysis was founded on a tainted, and unchallenged but critically important starting assumption: that aviation emissions in the then distant future should still be permitted at 2005 levels, pretty much their UK peak, and effectively imposed by the Labour government just a few weeks after the Climate Change Act became law. The target must have been signed off by then DECC Secretary and current ES&NZ Secretary … Ed Miliband. The legacy of this ‘2005-2050 equivalence’ continued on into CCC’s 2019 Net Zero report – which stretched the UKCB 2050 target from 80+% to something labelled as ‘Net Zero’ which, as we’ll see shortly, has a very significant and little-known meaning as it relates to aviation: its emissions would not reach Absolute Zero tonnage by 2050 but in fact an amount above that which would then have to be ‘offset’ in some way. At that end date every 1m tonnes CO2 above Absolute Zero matters, yet aviation was being granted a ‘licence to emit’ at a higher level, with the precise tonnage of that exceedance being determined flexibly by the changeable assumptions inserted by officials into pathway modelling and delivery risk calculations as these evolved over time.
Effectively this approach to the aviation pathway and end target constituted a DfT ‘land grab’ 40 years in front on what would be the absolutely minimal amount of CO2 that could still be emitted in 2050. It was and remains the foundation of both the DfT and CCC analysis and policy frameworks: an extraordinary privileging of just one relatively small economic sector. Yet, as part of this policy formation, neither DfT or CCC conducted an analysis of overall net economic/social welfare for UK plc of allowing that to happen.
So it was under Labour that aviation policy took off into a fantasy world of its own. But at this point we also need to fold in an additional and complicating twist to this story, relating to the partial responsibility of CCC itself for aviation’s ever-increasing share of transport emissions. It can be illustrated by this diagram (below; see enlarged image in the data note) that shows how, as part of CCC’s process in 2020 to prepare a proposed 6th Carbon Budget for the period 2028-32, it reconsidered the aviation emissions pathway CB6 would incorporate. Central to the analysis of its Aviation Sector Summary report was that aviation emissions were being driven upwards by an expansion in passenger demand. It therefore modelled a number of scenarios allowing for both increases and reductions in demand, alongside other factors including annual improvements in engine/fuel efficiency – which will tend to drive emissions onto a downwards trajectory as long as passenger demand is held level – and other techno-fix interventions (such as ‘sustainable aviation fuels’, electric aircraft etc).
There are scenarios which do put aviation on a glide path towards Absolute Zero, that is 0 tonnage emissions by 2050. The Tailwinds scenario (yellow pathway) analyses a reduction trajectory which drops below the 1990 baseline in around 2040 – thus also contributing to reducing the cumulative impact of aviation emissions eroding the overall UKCB – before actually attaining 0 tonnes in 2050. The most powerful assumption in this scenario, also shared with the Widespread Engagement scenario (green pathway) was that passenger demand would be constrained by a -15% reduction below 2018 by 2050.
But, partly influenced by 2019’s Climate Assembly (‘… A majority wanted to see a 25-50% increase in flights’) CCC opted for a preferred scenario (the ‘Balanced Net Zero’, purple pathway) which permitted a continuing further expansion of passenger demand (up to around 365mppa at 2050). A quick glance at the next diagram (below) appears to show CCC’s preferred scenario pathway reaching 0 tonnes in 2050 (the orange line; enlarged image in the data note) but its title includes the words ‘… with GHG removals’. Now go back to the previous page in the CCC report which quantifies the scale of those removals: ‘following the balanced NZ pathway, the remaining 23MtCO2e/year of gross remaining aviation emissions in 2050 would require 40% of total UK engineered GHG removals to be assigned to the aviation sector to achieve NZ within aviation CCC Aviation Sector Summary page 33, emphasis added.
It’s only at this point that the scale of the aviation ‘landgrab’ is revealed and apparently sanctioned by CCC itself. Cleverly when DfT came to produce its own Jet Zero strategy (JZS) two years later, its preferred emissions scenario closely mirrored the CCC 2020 one. In 2035 – 45 years into the 60 year NZ period 1990-2050 – both the DfT and CCC pathways were accepting that aviation could still be soaring way above its 1990 emissions baseline.
| 1990 baseline |
2019 actual | 2023 actual | 2023 modelled |
2025 modelled |
2030 modelled |
2035 modelled | 2035 as % 1990 | 2050 | |
| CCC CB6 2020 | 21 | 39 | 38.0 | 37.0 | 36.5 | 33.1 | 30.5 | +45% | 23 |
| DfT JZS 2022 | 21 | 39 | 38.0 | N/A | 36.8 | 36.0 | 33.6 | +60% | 15.4 |
But whilst the CCC preferred pathway allowed for +25% growth in passenger demand by 2050 – in fact no growth at all above the 2019 peak of around 300mppa until 2035 (except that this important qualification was omitted from the CCC’s headline communications) – all the DfT JZS scenarios were modelled on the basis of 70%* growth in passenger demand by 2050, and with demand constraint explicitly excluded from the JZS process (*subsequently reduced to 52% in 2023).
So unintentionally CCC had created a number of critical ambiguities in its preferred aviation emissions scenario and pathway which DfT would then exploit. By supporting an increase in passenger demand (even though less than known DfT ambitions), it licensed DfT to continue to promote and then respond to market demand by expanding capacity. By 2050 CCC’s preferred scenario didn’t even get aviation’s emissions below their CCA 1990 baseline (and this is before the extraordinary magnification of aviation’s non-CO2 impacts are added to the equation – see below). What CCC should have done is choose, or alternatively increase the policy emphasis on, those of its own scenarios which got the aviation pathway much closer to Absolute Zero.
This clash and indeed contradiction between possible emissions scenarios and differing passenger demand trends then sets up the current battlegrounds, for which however CCC is itself partly responsible and therefore now needs to make amends.
Current BATTLEGROUNDS 2024/2025
The Will Labour fail its transport decarbonisation test? report has a 15 page section on aviation (ps.30-45) which, amongst other things, presents a distillation of two recent reports by consultants Element Energy and Chatham House that identify the overwhelming advantage of deploying early passenger demand constraint. The report observes – relating to its Question 37: ‘The Jet Zero Strategy removes all regulatory controls over airport capacity, passenger demand, and emissions growth’:
‘What was not noticed at the time of JZS’s publication in July 2022 is the complete absence of mechanisms that could be used by government to manage, incentivise or constrain the level of aviation activity should that be necessary on climate grounds. They had quietly been excluded, which must have been the deliberate intention of the DfT. There is, JZS asserts, no need to constrain passenger demand [210], or airport capacity [211]. It must follow therefore that the level of aviation emissions will increase (relatively) following expansions of demand and/or capacity, and will be determined essentially by the market …The next government, should it choose to keep the JZS policy framework in place, will therefore have no levers available to restrict the growth of aviation emissions, annually and cumulatively’.
Consequently the report concludes that JZS is ‘deeply flawed because of its failure to construct its approach around the responsible management of climate risk’. In fact at the end of 2024 CCC is at odds with the government in relation to all three points of a malignant aviation ‘triangle ’ – passenger demand, airport capacity, emissions growth – because in its CB6 report and 3 successive Progress Reports (2022/2023/2024) it has provided advice or recommendations which the government has then dismissively ignored.
on passenger demand: ‘A demand management framework will therefore need to be developed and in place by the mid-2020s to annually assess and, if required, act as a backstop to control sector GHG emissions and non-CO2 effects.’ CB6 Policies report 2020 page 169
‘The Government’s announcements on aviation to date have not set any ambition to constrain aviation demand growth through policy, beyond vague proposals on carbon pricing, despite demand measures being one of the few interventions that lowers both CO2 emissions and non-CO2 effects from aviation. Given the risks outlined above, as well as risks of under-delivery on emissions reductions in other sectors, the Government should actively develop the option to implement policy to manage aviation demand.’ 2022 Progress page 325
on airport capacity: ‘The Committee’s CB6 Advice recommended no net expansion of UK airports to ensure aviation canachieve the required pathway for UK aviation emissions Since making this recommendation the Committee has noted that airports across the UK have increased their capacities and continue to develop capacity expansion proposals. This 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. 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. 2023 Progress page 267, repeated in 2024 Progress page 96
on aviation emissions: In its 26th October 2024 letter providing advice to government on setting its 2035 NDC target, CCC made this comment about IAS (international aviation & shipping) emissions (of which aviation will then make up 75%) that must be signalling its increasing anxieties about aviation’s ever-growing share of the UKCB. ‘Much stronger international action is urgently needed to address IAS emissions. According to CCC pathways, by 2035 IAS emissions will be the third largest source of emissions in the UK and by 2050 IAS will be the second largest source after agriculture.’ emphasis added.
This correlates to the ‘transport emissions numerator/UKCB denominator’ analysis in the previous Transport North article. The following table applies that same analysis but now to aviation’s share of total transport emissions (and then, in the bottom row, of the UKCB as a whole *The aviation percentage share of the UKCB in 2050 cannot be easily represented because by then the net carbon budget has been reduced to 0 tonnes).
| 1990 | 2019 | 2023 | 2025 | 2030 | 2035 | 2050 | |
| Total transport ‘denominator’ emissions -TTE MtCO2e | 153 | 168 | 152 | 152 | 126 | 88 | 25.1 |
| Aviation ‘numerator’ emissions | 21 | 39 | 38 | 37 | 36 | 33 | 23.3 |
| Aviation share of TTE | 13.7% | 23.2% | 25.0% | 24.3% | 28.6% | 37.5% | 92.8% |
| Aviation share of UK carbon budget | 2.5% | 7.9% | 9.0% | 9.0% | 11.7% | 16.8% | N/A* |
To summarise: as a consequence of deliberate government policy, aviation is indeed ‘eating the carbon emissions budgets’. By 2035 – that is, within the current policy horizon – aviation takes up 37.5% of transport carbon emissions and 17% of the UKCB as a whole. By 2050 aviation takes up 93% of transport emissions. Whilst CCC 2023 Progress states that ‘work to address non-CO2 effects must be accelerated’, and 2022 Progress notes correctly that ‘the most effective way of mitigating non-CO2 emissions is through controlling demand for aviation’, it can be judged a mistake that CCC has so far not made a definitive recommendation concerning the formal treatment of non-CO2 impacts within the aviation policy framework.
As for the Labour government’s position, so far as it can be known:
– A whole series of airport expansion applications or aspirations have been coming forward (as encouraged by the JZS and associated policy frameworks): Gatwick +29mppa; Stansted +8m and possible +20m; Luton +1m and possible +13m; Bristol +2m and possible +3m. Waiting on the taxi-ing runway would be Heathrow which would resurrect its 3rd runway proposal (already supported by Parliament); and many smaller regional airports are ‘stretching their wings’. The London City Airport planning application was approved by Labour less than a month after CCC 2024 Progress repeated its recommendation against any expansions; the Luton 13mppa application is due to be decided by 3rd January with a Gatwick decision just a few weeks later. [Stop Press!: As this article was being uploaded on 17th December the government announced the Luton expansion decision was being postponed for another 3 months.] Research by NEF’s Alex Chapman indicates that, over time, emissions generated by the expansion of just Gatwick, Luton and particularly Heathrow would eat into, even negate, the emission savings produced by Labour’s priority Clean Power Plan.
– The government has made no statements about either of future levels of passenger demand or aviation emissions, silence about which must act to encourage expansionist aspirations
– There have been repeated statements by the Prime Minister and Chancellor in support of airport/aviation growth, which have been designed to imply (but without evidence or analysis) that ‘airport growth will be good for economic growth’. This is also the position of an influential phalanx of Northern regional mayors (from Andy Burnham in Greater Manchester onwards) who have sought to position airport growth within the frame of industrial strategy. And here’s the statement from aviation minister Mike Kane (MP for the constituency which includes Manchester airport) to the UK Airports conference just two weeks ago:
aviation & economic growth: “If Britain is to grow, aviation has to grow. … Your success is mission critical for this government. … You have an outsize impact on our economy’; aviation decarbonisation: ‘By 2050, as things are going, aviation will be the second largest emitter of carbon in the UK. … I want aviation to grow, but I want it to grow sustainably. We have to address our carbon emissions and aviation will be key. … “I want as much SAF as possible made in Britain.’; Regulatory relationship: “My job is to fight for you day in and day out and give you the conditions to thrive.’
The aviation minister seems to understand his role as promoting the narrow interests of his specific industrial sector rather than promoting the much wider public interest., and in a way that ignores evidence in favour of simple assertion. As commented on above, CCC has never assessed and concluded that it is an optimal outcome for UK plc to ‘assign’ almost half of the UK’s 2050 capacity to sequester residual CO2 to this one economic sector – at present valued at just 1.5% of UK GVA (direct contribution, airlines+airports). But it has been the DfT’s deliberate choice to promote increased passenger demand which will principally benefit just a small proportion of wealthy frequent flyers, as against capping that demand which would then result in annual, automatic incremental emissions reductions to the benefit of both the climate and all the economy/society.
As article 2 concluded in relation to the DfT decision not to promote incremental, early reductions in transport’s carbon emissions: ‘This could only have come about because of an extraordinary DfT policy failure over the 15 years since the 2008 CCA but which probably had its origins in the decade beforehand’. This is even more so in the case of aviation, so what should CCC do now to rectify its unintended contributions to this government failure which include: its analytical dithering around levels of passenger demand, insufficient tonnage reductions in the aviation emissions pathway, and its absence of clarity on non-CO2 impacts policy inclusion?
The PROBLEMS to be resolved & TASKS to accomplish in CCC’s CB7 report
It’s been a complicated story so far reaching back 35 years but what it does is bring us is to a point at the end of 2024 where we can ask and answer the question: how can the Climate Change Committee discharge its responsibilities to analyse and propose an aviation CO2e budget and pathway that better recognises the science; better manages the future climate risks stacking up inside the UK carbon budget; and then secure greater government acceptance of its recommendations?
On 25th February 2025 CCC will publish its proposed 7th Carbon Budget report covering the period 2038-42, thus really beginning its glidepath towards landing the entire UK net zero carbon budget in 2050. (As a ‘scene setter’ here’s the February comment from Prof Greg Marsden, Leeds ITS on the transport issues CB7 should be responding to, together with a paper on the proposed CB7 methodology). At the moment the close mirroring between the existing CCC and DfT aviation emissions pathways pathways is allowing DfT to be able to say that, in essence, its pathway is intending to implement the emissions pathway that CCC are recommending.
This must create strong doubts about the integrity and effectiveness of the CCC pathway, because it’s now providing the Labour government with an alibi and justification for continuing passenger and capacity expansion despite the fact that this is now in contradiction with the CCC’s own strongly communicated ‘no expansion’ recommendations. It’s a reasonable conclusion that the current CCC aviation emissions pathway has been compromised and cannot continue as an internally consistent proposition. If that’s the case then it would follow that the CCC CB7 aviation emissions pathway must be revised and relaid downwards. This has significant top-level benefits: it would then help prevent ‘aviation eating both the transport and UK carbon budget’, which might in turn allow the ES&NZ Secretary of State to bring forward a lawful UKCB with properly managed risks in May 2025.
Can we define some principles, objectives and actions that CCC needs to deploy in order to achieve this? It should ensure that the aviation emissions pathway for the next 25 years properly integrates all emissions contributing to aviation’s radiative forcing rather than omitting some which are already well understood and are hugely magnifying. It should reassert a fundamental requirement that the starting point for aviation emissions should be reduction below the 1990 baseline and the endpoint Absolute Zero. If both passenger demand and airport capacity are capped, modelled scenarios would then identify how much further and faster the emissions pathway could be reduced. It’s clear that the process of setting of CB7 across the period maybe up to October 2025 is the last opportunity to begin to make these pathway corrections.
* * * * * * * * * *
“With major expansion decisions on the immediate horizon, it’s essential that we pause now to consider the issues raised in this analysis. It’s clear that aviation has been afforded generous treatment since the Government of the day set an emissions stabilisation target for the sector back in 2009, and while sectoral targets have since transitioned towards net zero, these mask the scale of forecast residual emissions from aviation in 2050 which will still exceed their 1990 baseline. When you factor in the need to address aviation total climate impacts, and not just aviation’s CO2 emissions, the stark reality is that we need a steeper emissions reduction trajectory, especially in the 2030s. The suggestions put forward in this article are an appropriate place to start a fresh analysis that can put the sector back on track.”
Tim Johnson, director Aviation Environment Federation
* * * * * * * * * *
ACTIONS that CCC needs to take in its forthcoming CB7 report
1 Non-CO2 impacts: The discussion in this article so far has been about the CO2 impacts of aviation but the nature of where its emissions take place (mostly at altitude) means that a basket of shorter term non-CO2 effects also occur. The science behind this is complex but all the reader needs to know is that: an assessment of actual non-CO2 impacts over the last two decades shows that they make up a larger proportion of the combined radiative forcing than the CO2 ones; the non-CO2 impacts are excluded from the DfT policy framework (on the grounds that future impacts are subject to uncertainty); and that so far CCC has not made a recommendation about their inclusion in that framework. To approximate: alongside every 1 unit of CO2 impact should be counted an additional 2 non-CO2 impacts (thus a 33%/66% ratio). Consequently at present there is a huge undercounting of aviation’s aggregated climate impacts, and the continued exclusion of non-CO2 impacts from the policy framework means that ‘they disappear from view’ so far as constraining actions are concerned, and there are no incentive slopes acting to reduce them.
This position is no longer tenable and the fact that future non-CO2 impacts are inherently uncertain needs instead to be encompassed within the policy framework. The CCC 2009 aviation report page 22 did identify three ways in which non-CO2 inclusion could be achieved within that framework but 15 years later this situation has still not been resolved. It’s suggested that – seeing that CB7 is setting the policy framework closely adjacent to 2050 after which CCC says there should be no further non-CO2 effects – i) taking action on non-CO2 impacts must now be formally incorporated as a requirement into the CCC recommended policy framework, even if ii) actual numbers (or a metric) are not yet attached to it. Immediately iii) the modelling and displaying of parallel trajectories for both CO2/non-CO2 impacts should be undertaken so as to make visible to policy makers, the industry, passengers and the nonflying public the scale of aviation’s damage to our climate. This would lead to iv) CCC recommending that a programme of interventions to reduce non-CO2 impacts is required to be developed.
2 In view of the risks to the overarching UKCB 2035/2050 targets it has already acknowledged, CCC should now review the choice between the aviation emissions pathway scenarios in its CB6 report, such that the 1990 baseline established by the CCA should be restored as the emissions tonnage limit aviation must reduce from, and in order to both minimise aviation’s cumulative erosion of the UKCB and its 2050 Absolute Zero emissions. This revision should include the assessment of both CO2 and non-CO2 impacts.
3 CCC should review how the assessment of ‘backended’ future aviation emissions reduction delivery risks across 2020s/30s/40s should be reflected in the ‘frontended’ policy frameworks in order to manage those risks downwards (e.g by using a process of backcasting).
4 CCC should also review how the actual economic benefits of aviation are modelled and analysed in both its and governments assessments in order to justify, and if necessary rebalance, aviation’s privileged position within the ‘whole- economy’ policy framework across to 2050.
5 On the basis of 1-4 above CCC should prepare scenarios for a new aviation emissions pathway whereby i) the sector reduces its emissions below their 1990 baseline at the earliest date; ii) attains the lowest possible Absolute Zero emissions in 2050; and iii) and which treats the aviation sector on an equal basis as all other economic/social sectors (as against being uniquely privileged).
6 In order to give effect to this revised emissions pathway CCC should then recommend an approach whereby i) future passenger demand can be capped at a level consistent with the new pathway (but no higher than the pre-Covid 2019 peak), and ii) airport capacity can be similarly capped. This would involve an extension of the existing CCC recommended capacity management framework and utilise a variety of regulatory and fiscal mechanisms.
7 To encourage the use of technological (and other) interventions as JZS does, CCC should recommend the deployment of proper incentive slopes that both i) support that technological transition but also ii) constrain continuing fossil/carbon related fuel use. The i) incentives should be funded by the industry/users and not from public expenditure, whilst at present there are insufficient ii) incentives being applied despite the fact that multiple options are in fact available. This situation is hindering progress with JZS’s preferred method for emissions reduction.
8 Alongside the CB7 proposals, and in response to a continuing pattern where i) the UK government (whether Conservative or Labour) is choosing not to adopt CCC recommendations for the aviation sector, and ii) in consequence is increasing the risk of non-delivery of the overall NZ 2050 target, CCC should reach an understanding with government as to whether or not it intends to respect CCC recommendations relating to the constraint of aviation emissions. The outcome of those discussions should then be made public. As part of any agreement, IAS formal inclusion in carbon budgets under CCA section 30, promised a number of years ago but not fulfilled, must be legislated.
WHAT will CCC and the Secretaries of State Miliband and Alexander DO NEXT?
These are a radical set of proposals aimed at reducing the increasing risk that the aviation sector on its own poses to the UK carbon budget and removing the unjustified privileging that it receives within the government policy frameworks. What are the chances of them being considered at all, let alone taken forward? No doubt CCC has mostly already completed its work preparing the approach to CB7, and maybe that might be proposing simply a ‘steady as you go’ continuation from CB6, even though that is heading for a crash landing.
It’s easier to predict that a Labour DfT and government will give as little heed to such suggestions as they have done to recent CCC recommendations. The government’s response yesterday to CCC Progress 2024 resorted to misleading spin when it claimed ‘we have taken decisions which mean we are already acting or partially acting on all 35 of the CCC’s recommendations to the UK Government’. Those included ‘no airport expansion’ and yet the response page 62 effectively declares its rejection of that recommendation: ‘The government recognises a role for airport expansion …’
Maybe both government and CCC should revert to the approach they undertook in 2009, where – in response to the CB7 proposals published in February Energy Security & NZ Secretary Ed Miliband could write another letter to CCC as was done in January 2009 but this time (to paraphrase that previous request) asking their advice on i) what action CCC would recommend in relation to current proposals for airport expansion and whether these are compatible with the aviation and UKCB emissions pathways. (This would follow a sensible decision in January 2025 to ‘pause’ all current applications awaiting approval so as not to undermine the CB7 analysis before its publication). And ii) what CCC itself would recommend as an aviation emissions pathway and 2050 target which it believes is compatible with a lawful NZ strategy with minimised delivery risks. The Committee could also be asked to advise on how the process of transition to such a new pathway can be accelerated by a combination of demand and capacity constraints, technological innovation (supported by incentive slopes) and regulatory/fiscal mechanisms.
Let’s say that the Labour government, and secretaries Miliband and Heidi Alexander choose not to go down this route at all. Approving more airport expansions in the New Year would make their flouting of CCC recommendations against this systematic. Well, 25th February is still a couple of months before 3rd May, the deadline set by the courts for the former to propose a lawful NZ Strategy under CCA section 13. Maybe in that intervening period, and then in the months afterwards – whilst the merits, strengths and weaknesses of the CCC’s proposed CB7 are subject to public debate, before its Parliamentary adoption – the campaigners and commentators could urge both CCC and the government to take a responsible policy position towards this irresponsible sector.
In a paper published the day before this article was finished, Prof Jillian Anable of Leeds ITS (pursuing a very similar analysis to that in the Labour decarbonisation test report and these articles; I’ll take that as a compliment) – and which concludes that ‘if transport decarbonisation fails, net zero will also fail’ – suggests that ‘A radically different decarbonisation pathway for transport is now an imperative to start to make deep cuts over the next half a decade. But what might this consist of …?’ However her menu of possible interventions does not include the contribution that a reduced aviation emissions pathway might make.
But if the government does not respond, then surely arguments such as those explored in this article could make a contribution to the legal action that Friends of the Earth may find it necessary to take, on the grounds that because ‘aviation is eating the transport carbon budget’ and ‘transport is eating the UK carbon budget’, it’s manifestly impossible for Secretary of State Miliband to fulfil his responsibilities under the CCA, of which he was the original champion. And it’s the strengths of those opportunities for judicial review, if necessary, that is the subject of the fourth article ‘Legal showdown: the DfT versus the Climate Change Act, to be published on 28th December.
My thanks to Tim Johnson, director of the Aviation Environment Federation for his assistance with technical aspects of this article.
Comments/questions about this article to info@transportnorth.org.uk
Precautionary caveat: The analysis of this article – that transport’s uniquely large and rising share of the UK carbon budget is such that it will be difficult if not impossible for the government to propose a lawful climate plan in 2025- is a hypothesis which can only be proven by quantified modelling. This would need to be undertaken i) by the government itself in the form of a scenario demonstrating the opposite, and/or ii) by CCC within the modelling it is now undertaking for CB7.
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The fifth and final article in this series will be ‘Six months in: the answer to our question is …??’, returning to the ‘test’ established by the title of our original report – 4th January 2025