Comment: TfN’s transport strategy recklessly encourages aviation carbon growth

Anthony Rae writes 9th March 2018  In the previous article ‘Does the draft TfN strategy pass the crucial ‘carbon test?’ – looking at TfN’s preliminary quantification of the carbon consequences of their plans – we noted that the figures from that modelling however ‘omitted the additional contribution of aviation carbon, the expansion of which the TfN strategy is seeking to promote.’ The STP had also quoted the government’s own Clean Growth Strategy ‘identifying transport, which accounts for 24% of UK emissions’. whereas we pointed out that the full extent of transport impact on UK carbon budgets was properly acknowledged, by DfT themselves, as not 24% but 36% when international aviation (and shipping) is included.

Now carbon dioxide is a colourless and therefore invisible gas, but it’s particularly invisible to transport policy and decision makers. When repeatedly reminded, the TfN planners have eventually accepted that the carbon emissions from surface transport exist, consequently have to be considered under the locus of the Climate Change Act (CCA), and therefore must be modelled and measured in order, just possibly, to then be managed downwards. But apparently the carbon dioxide emanating from aeroplane engines is just … different, and not ‘transport’, and therefore can once more disappear from view.

If you were to think that this mild sarcasm is slightly unnecessary then consider the case study relating to another TfN preparatory document feeding into the STP: its grandly named Independent International Connectivity Commission Report, published in February 2017. Another reason why aviation carbon gets overlooked is that keeping track of its analysis is slightly technical, so very few stakeholders are going to be in a position to challenge what’s put in print. But as a campaigner who has prepared the aviation analyses for the likes of Friends of the Earth and Campaign for Better Transport, I was somewhat incensed when I first looked through its pages and understood its implications.

What had caught my eye was this statement: “To deliver this step change [in GVA], we will need to create the conditions where the volume of international airport passengers can grow to 75 million passengers per year in 2050, which is 12 million higher than currently forecasted by DfT.” Its significance is twofold: its laudatory tones of ‘growth is good’ – which continue throughout the entire document – appeared quite unaware that an increase in passenger numbers also results in an approximately similar increase in carbon emissions, in the situation where the CCA requires everyone to plan for carbon reduction; and secondly that it seemed blissfully unaware of the policy context within which it was operating: that the Committee on Climate Change has established a ceiling for aviation passenger/ATM growth which cannot be exceeded without jeopardising the UK’s entire 2050 carbon budget; that the DfT forecasts were nonetheless planning to do just that; and yet here was TfN enthusiastically proposing to breach even those limits!

Reading on through the report uncovered many more elementary ‘misunderstandings’ of this type. So I asked for an opportunity to ‘challenge’ the report and its underlying analysis, and in August 2017 had an amicable discussion with the TfN Head of Strategy and the aviation consultants who had assisted with its preparation. These are some of the points I made:

– the so-called ‘independent commission’ that produced the report had no stakeholders representing an environmental perspective – in fact they were all from a business background – so did not sufficiently challenge as they should have done a pro-aviation industry analysis that would inevitably be produced by TfN’s chosen consultants. The words I used were that the commission was ‘both credulous and inexpert’.

– the report seemed completely unaware of the need to locate its ambition of major aviation expansion in the North within a framework requiring an interaction with the contradiction between the carbon constraint frameworks established by CCC and DfT respectively (as above), and consequently ended up apparently proposing an even more flagrant breach of the CCC framework for aviation carbon, and therefore of the overall UK carbon budgets adopted by Parliament.

– in advancing a proposition that the aviation market in the North needed to be assisted to expand by additional public sector interventions, the commission did not seem to be aware that the UK aviation market on its own is already expanding at rates much higher than UK GDP growth – to the extent that the DfT forecast for 2020 UK passenger numbers (255m) had already been easily surpassed by 2016 (267m), four years early – and as a result of factors inherent to its low-cost business model. This consequently renders ‘public support for growth’ entirely unnecessary.

– the report did not acknowledge anywhere that government policy relating to the commission’s principal method of proposed market intervention – what it calls ‘improved surface access’ – requires that the principal funding partners in such projects should be the airports themselves; whereas with the exception of Manchester, none of the Northern airports are in any position whatsoever to make the level of contributions required by government policy, nor have stated any intention to do so. (This policy requirement – reaffirmed in DfT The future of UK aviation 2017 para.7.10 – was recorded in the consultants’ evidence report, but omitted from the commission’s.) To propose as its first priority a major but also uncosted public investment programme where policy requires large-scale private operator investment, but where the latter is in fact not available, is to send policy/decision makers off in completely the wrong direction.

– during the discussion there were repeated references from the TfN/consultants side to possible reallocation or transfer effects that might occur, always to the benefit of the North: of airside trips relocating between southern and northern airports; of surface access emissions reallocating and reducing; of carbon emissions reallocating between global locations, or different sectors; and so on. It’s easy to make such claims in theory but the proper test requires a quantification that would demonstrate whether such effects either do or do not exist, and of course that had not been done.

As it happens these were just the headline criticisms of what was a deeply flawed report, and there were many more that could have been added. And whilst we did talk around some of the technical detail of the above, with views on both sides, what TfN were not able to do was point to some, indeed, any elementary mistakes in the issues raised as a way of actually refuting them.

So that was August 2017. What happened next, as a result of this ‘challenge’ to the credibility of an important TfN report? At the time I had made the general point about the TfN strategy process, that it was no good such criticisms being expressed retrospectively as a post-hoc critique, in the context of a report that has already been published, with any challenging views quite unavailable to its readers.

Fast forward to January 2018 and the publication of the STP; and what do we find, on page 29?: “Under a transformational growth scenario, it is predicted that there will be 75 million international air passengers per year by 2050, which is 12 million more than the business as usual scenario trajectory. Achieving this level of growth will require significantly improved surface access to airports across the North.” TfN had apparently concluded that the best way to deal with this particular challenge to a significant part of their thinking was just to ignore it. Who, after all, will know?

Why does this matter, in addition to spotlighting shortfalls in the TfN strategy and governance process? In fact it’s much more serious than that. Back to that apparently invisible carbon dioxide, and our main article about it , which had recorded TfN’s preliminary projection of a 9-14% reduction in carbon emissions by 2030 from surface transport as a result of implementing its strategy. So without aviation carbon!

Add that back in and … well, what have we got? – because TfN’s International Connectivity report didn’t bother to mention aviation carbon, let alone count it. DfT are projecting a 16.6% increase in UK aviation emissions (if Heathrow 3rd Runway gets built, which is their intention) between 2016-30 DfT 2017 forecasts table 70; as we’ve noticed their current passenger growth forecasts have already been exceeded; and then TfN want to add on top of this another big dollop of Northern aviation growth … and therefore emissions growth.

I’m not going guesstimate the size of this northern aviation carbon surge (it’s TfN’s responsibility to precisely calculate it) but it’s obvious that their projected 9-14% carbon reduction – already wholly inadequate compared to the Committee on Climate Change’s recommended 44% reduction by 2030 (on the assumption that its parallel aviation carbon ceiling is also kept to) – has been further substantially eroded. And this in a situation where the tensions within the entire UK carbon budget already put its delivery on a knife edge.

Lord Deben, CCC’s chair, has recently been encouragingly determined in his public statements to the effect that aviation’s already hugely generous carbon allowance within that budget (and also transport’s allowance as a whole) have to be rigourously adhered to; see his HoC Transport Committee witness session 18th December 2017. But both DfT and TfN alike have apparently determined – whether consciously or otherwise – to push to the limits the entire UK carbon reduction framework embodied in the Climate Change Act, by a half-hidden actual promotion of transport carbon expansion!

That’s just not acceptable.

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Footnote: And who chaired the independent commission that produced TfN’s International Connectivity report? Sir John Cridland – also chair of the TfN board. Maybe that’s why any criticism of it has to be ignored, and why within TfN there has been a quite inadequate understanding of the relationship between aviation growth and its carbon consequences.