Jet Zero Consultation - Draft Answers for GALBA Supporters
Jet Zero consultation - draft answers for GALBA supporters
The following are suggested answers to Jet Zero’s consultation questions. It’s better if you can use your own words but if you don't have time, feel free to use the text below. Please send your reply before 8 September to: NZaviationconsultation@dft.gov.uk
1) Do you agree or disagree that UK domestic aviation should be net zero by 2040? How do you propose this could be implemented?
Agree. However, domestic flights account for just 4% of UK aviation emissions so greater ambition is needed for international aviation. One key implementation measure that is not in Jet Zero is to immediately stop the expansion of UK airports and impose other measures (including taxes) to manage demand downwards in the crucial next 10 years. Another measure would be to make it illegal to fly internally for journeys less than 600 miles, with exceptions for remote communities and emergency flights.
2) Do you agree or disagree with the range of illustrative scenarios that we have set out as possible trajectories to net zero in 2050? Are there any alternative evidence-based scenarios we should be considering?
Disagree. The scenarios in Jet Zero are themselves not adequately evidenced based. If there is more evidence, it has not been adequately presented, either in the consultation document or in the supporting document. Jet Zero itself says: “There is significant uncertainty surrounding the abatement potential, uptake and costs of the measures described in this document and therefore these scenarios should be seen as illustrative pathways rather than forecasts.” In reality, there is no realistic scenario or forecast in which technological and fuel developments can, on their own, make flying net zero by 2050. As the Climate Change Committee has advised, demand management measures (including taxes), including an immediate halt on all airport expansions, are essential to control aviation emissions in the next 10 years.
3) Do you agree or disagree that we should set a CO2 emissions reduction trajectory to 2050?
Agree. But the measures proposed to achieve that reduction must be realistic, evidence based and reliable. As advised by the IPCC, we must make actual emissions reductions by 2030 - Jet Zero proposes an increase. The high level of uncertainty attached to all of Jet Zero’s technical solutions (which is accepted in Jet Zero itself) means that demand management measures are urgently required in addition to the proposals set out in the draft strategy.
a. Should the trajectory be set on an in‑sector CO2 emissions basis (without offsets and removals) or a net CO2 emissions basis (including offsets and removals)?
In‑sector CO2 emissions basis. Offsetting should not be used to count towards reaching net zero, as advised by the CCC in the 6th Carbon Budget. Offsets are at best an addition, not an alternative, to controlling emissions in the next 10 years.
b. Do you agree or disagree with the possible trajectories we set out, which have in-sector CO2 emissions of 39 Mt in 2030, and 31 Mt in 2040 and 21 Mt in 2050, or net CO2 emissions of 23-32 Mt in 2030, 12‑19 Mt in 2040 and 0 Mt in 2050?
Disagree. Climate scientists on the IPCC and the CCC warn that we must make radical cuts to emissions in the next 10 years in order to have any realistic prospect of reaching net zero by 2050. It is deeply irresponsible to propose allowing aviation emissions to increase up to 2030 and such a policy would contradict the government’s new target of cutting UK emissions by 78% by 2035. There are no special reasons to allow the aviation industry to increase its emissions while all other sectors must reduce them. Jet Zero presents no evidence to suggest that other sectors could reduce emissions by more than 45% to compensate for aviation’s increased emissions.
4) Do you agree or disagree that we should review progress every five years and adapt our strategy in response to progress?
Disagree. The urgent nature of the climate emergency and the need to radically reduce emissions in the next 10 years means that there should be annual reviews of the aviation industry’s emissions and the extent to which they are (or are not) reducing. Government strategy should rapidly adapt if emissions are not reducing at all or not reducing fast enough.
5) Do you agree or disagree with the overall approach to improve the efficiency of our existing aviation system?
Disagree. The assumption of 2% pa efficiency gains is a dangerous over-estimate and is not based on credible evidence. Evidence from the CCC and ICAO shows that 1.4% pa is the highest realistic rate.
6) What more or differently could be done to ensure we maximise efficiency within the current aviation system?
There may be further measures but there is no reason to believe they would be adequate to control emissions sufficiently in the next 10 years. That is why the government should immediately implement demand management measures (including taxes), starting with the prevention of all UK airport expansions.
7) Do you agree or disagree with the overall approach for the development and uptake of SAF in the UK?
Disagree. First, there are huge uncertainties about the potential for scaling up SAF production and associated infrastructure development, such that SAF cannot reasonably be relied upon to the extent proposed in Jet Zero. The area of land required to grow enough crops to produce biofuels to power an unconstrained increase in flying, and meet our other needs, would be vast. Secondly, this is a priority need solely for the aviation industry so the aviation industry should meet the full cost of developing and deploying SAF. It should not be borne by the taxpayer as there are more effective uses of public funds to mitigate the climate crisis and adapt to its unavoidable impacts. A small minority of the UK population take the majority of flights while a significant proportion of the population does not fly at all in any given year. The cost of developing SAF should be borne by those who will use SAF.
8) What further measures are needed to support the development of a globally competitive UK SAF industry and increase SAF usage?
Time. However we do not have the luxury of time so demand management measures (stopping the expansion of UK airports, taxing aviation fossil fuels and/or emissions and using APD to increase ticket prices) should be introduced immediately to manage demand downwards in the next 10 years.
9) Do you agree or disagree with the overall approach for the development of zero emission flight in the UK?
Disagree. Electric flight will not be viable for anything other than short haul, small aircraft, even by 2050. Hydrogen flight faces huge obstacles and uncertainties regarding its development, scaling up and commercial deployment, such that hydrogen cannot reasonably be relied upon to the extent proposed in Jet Zero.
10) What further measures are needed to support the transition towards zero emission aviation?
The immediate introduction of demand management measures to manage demand downwards in the next 10 years. Introducing taxes on aviation fossil fuels and their resulting emissions, at a rate that realistically reflects their climate damaging costs, is an urgent priority. These measures are essential, if only to provide ‘breathing space’ for the development, testing, monitoring and commercial deployment of the technical solutions proposed in Jet Zero.
11) Do you agree or disagree with the overall approach for using carbon markets and greenhouse gas removal methods to drive down CO2 emissions?
Disagree. Offsetting does not ‘drive down’ emissions. The UK ETS and CORSIA are inadequate methods to meaningfully offset aviation emissions. There is very little risk of ‘carbon leakage’ from domestic UK flights or flights from the UK to EU destinations, so the ETS as currently constructed will not reduce emissions. The CCC specifically rejected counting CORSIA offsets towards the UK’s 2050 net zero trajectory.
Greenhouse gas removal (GGR) technologies are nascent and the timescale for their scaling up is very uncertain, such that they cannot reasonably be relied upon to the extent proposed in Jet Zero. The immediate introduction of demand management measures (including taxes) to manage demand downwards in the next 10 years is vital to limit the amount of emissions that will need to be removed in future.
12) What could be done further or differently to ensure carbon markets and greenhouse gas removal methods are used most effectively?
Make the price for each tonne of CO2e offset credit equivalent to the actual cost of GGR technologies that have been proven to remove emissions from the atmosphere. Properly apply the ‘polluter pays’ principle by the immediate cessation of giving free credits to the aviation industry via the UK ETS.
13) Do you agree or disagree with the overall focus on influencing consumers?
Agree but they will not be adequate on its own to influence consumers’ choices. The government should introduce demand management measures as soon as possible to manage down demand for aviation in the next 10 years.
14) What more can the Government do to support consumers to make informed, sustainable aviation travel choices?
Introduce significant taxes on aviation fossil fuel (the polluter should pay) and use APD to increase ticket prices. Switch public subsidies to low carbon, ground transport in order to make the sustainable choice, the cheaper choice.
15) What could be done further or differently to ensure we tackle non-CO2 impacts from aviation?
Implement the CCC’s priority recommendation in its Progress Report to Parliament in June 2021: “There should be no net expansion of UK airport capacity unless the sector is on track to sufficiently outperform its net emissions trajectory and can accommodate the additional demand. A demand management framework will need to be developed (by 2022) and be in place by the mid-2020s to annually assess and, if required, control sector GHG emissions and non-CO2.”