Cross-party MPs on the UK Parliament’s Environmental Audit Committee have welcomed government policy steps to scale up and support new technologies, zero carbon aircraft and domestic sustainable aviation fuel production in efforts to reach a sectoral target of net zero emissions by 2050. However, its Net Zero Aviation report just published expresses a number of concerns over the government’s Jet Zero Strategy and notes its high ambition scenario needs to be followed through with “vigour and the appropriate priority” for delivery or risks the UK falling behind in its emissions reduction targets, leaving other sectors to pick up the slack. The Committee calls on the government to undertake an early review of progress by the end of 2025 and to urgently consider further demand management measures should reductions fall short of prediction. The government must also carry through on its legislative promise to include international aviation emissions in the national carbon budgets, they say. The MPs welcome the establishment of a mandate for SAF use and call for swift progress on introducing a revenue certainty mechanism to support SAF developers. Meanwhile, a group of NGOs has written to the government seeking assurances that such a mechanism would be funded by the aviation industry and not the taxpayer.

Commenting on its report, a member of the Committee, Jerome Mayhew MP, said aviation’s decarbonisation path was substantially slower than that of many other sectors of the economy and would require a number of different initiatives to make a tangible impact.

“First, the correct legislation needs to be in place. Despite promises over the years, the government is yet to include aviation emissions in its carbon budgets, which monitor progress in the UK’s emissions reduction policies,” he said. “Second, we must support industry in developing new technologies and fuels, and provide the right certainty and definitions for what can be coined a ‘sustainable aviation fuel’. These new technologies must not only reduce CO2 emissions, but take into account and mitigate other environmental impacts associated with aviation. And finally, we must champion UK innovation on zero carbon aircraft here at home for UK flights.”

In 2019, the UK’s aviation emissions amounted to 37.8 MtCO2e – 36.4 MtCO2e from outgoing international flights and 1.4 MtCO2e from domestic flights – together accounting for 8% of total UK GHG emissions. Having fallen substantially during the pandemic, emissions are expected to climb as traffic recovers to pre-pandemic levels, potentially this coming year. The government’s independent advisory Climate Change Committee (CCC) predicted in 2019 that unabated, aviation was likely to be the largest emitting sector in the UK by 2050, consuming 36% of the available carbon budget.

The CCC’s projections for 2050 under its ‘balanced net zero pathway’ modelling envisage aviation contributing 23 MtCO2e to the UK’s emissions, set against a baseline of 51 MtCO2e. The reduction of 28 MtCO2e comprises a contribution of 12 MtCO2e from demand management, 8 MtCO2e from SAF and 8 MtCO2e from efficiency measures and hybrid fuels. This was based on a number assumptions, including that by 2050 demand would have grown by no more than 25% relative to a 2018 baseline, the sector would improve its efficiency by 1.40% annually to 2050 and by the same year, 17% of UK aviation fuel would be from biofuel and 8% from synthetic fuel.

By contrast, the government’s own modelling, which underpins its Jet Zero Strategy assumptions, projects traffic demand would rise by 70% by 2050, airline fuel efficiency would increase 2% annually between 2017 and 2050, and SAF would be providing 10% of aviation fuel by 2030, 22% by 2040 and 50% by 2050.

Through its Sustainable Aviation body, the UK aviation industry’s modelling shows different projections from both those of the government’s and the CCC’s, with a much higher forecast of unabated aviation emissions but markedly more optimistic contributions from new fuels and technological efficiencies in aircraft fleets, including zero-emission aircraft. As a result, the industry’s projection of the 2050 ‘emissions gap’ – residual emissions unable to be mitigated by action within the aviation sector – appears far lower than the CCC and government estimates, notes the EAC report, which recommends the government work with the CCC and Sustainable Aviation on a comparative analysis in order to reach a consensus.

Over two and a half years after promising to bring legislation to include international aviation emissions in the UK’s Sixth Carbon Budget target by 2037, the MPs recommend the government lay before Parliament a draft statutory instrument “without further delay”.

The government has committed to five-yearly reviews of progress against the Jet Zero Strategy’s targets, which, on the current timetable, would make the first review in 2027, which the EAC believes is too late.

“We recommend that an initial review of the Jet Zero Strategy and the modelling underlying its ‘high ambition’ scenario be undertaken no later than the end of 2025, with a view to determining whether the Strategy remains on track to meet the interim emissions reductions projected for 2020 and 2040, as well as the overall reductions projected for 2050,” says its report, which adds that it should be with the active engagement of the industry.  

“Should the evidence of the review indicate that technological measures alone will not deliver the emissions reductions predicted, we recommend that ministers reconsider the role of demand management measures in aviation emissions policy. In preparation for the outcome of that review, we recommend that the government develop policy proposals on demand reduction, including consideration of greater use of digital technologies, reducing the cost of rail travel and a frequent flyer levy, should these then by required.”

The MPs on the Committee were encouraged by the research and development taking place in the UK on zero emission flight technologies, recognising their deployment is realistically likely to be restricted to short-haul flights for the foreseeable future. They recommend the government establishes a target under the Jet Zero Strategy for the full roll-out of zero-emission aircraft on a minimum number of routes essential to UK connectivity by 2040. When promoting research into the non-CO2 effects of aviation, the government should also include the funding of research into the effects on the atmosphere and climate of aircraft using zero-emission flight technologies.

The Committee welcomes the initiatives taken so far by the government to establish a domestic industry for the manufacture of SAF and its efforts to build long-term supply chains internationally, and also the criteria restricting the feedstocks to be used in UK-manufactured SAF and specifying that feedstocks are not to be obtained from land with high biodiversity value or land with high carbon stocks.

However, it is concerned about the broad definition of what is considered ‘sustainable’ and in the absence of a global standard for SAF, that this might lead to the development of aviation fuels that cannot credibly be described as such.

“We recommend that the government takes every opportunity to establish in its policy instruments for a UK SAF industry the strongest safeguards to ensure significant lifecycle emissions savings from the use of SAF developed in the UK,” says the report. “We further recommend that ministers and officials work vigorously at ICAO and in all other relevant international bodies for the establishment of a global regulatory standard for SAF which is comprehensive and rigorous.”

It also calls for “swift progress” on the implementation of a price support mechanism to incentivise investment for new SAF production pathways.

“The Committee’s report sets out clearly what the government must be prioritising, and I look forward to receiving its response,” said Mayhew.

A group of ten NGOs is also looking for a response to a letter they have sent to UK transport ministers urging the government to follow through with its intention that a SAF price support, or revenue certainty, mechanism should be funded solely by industry. The group, which includes Greenpeace, Opportunity Green, Transport & Environment and the Aviation Environment Federation, seek clarification that all the costs of such a scheme are entirely funded by the aviation sector and that existing or future taxes or revenues that flow to the Treasury, such as Air Passenger Duty or from the UK ETS, should not be earmarked for the fund. Given that the majority of British people did not fly, it would be “grossly unfair” for taxpayers to cover the funding costs, they argue.

“At no point should there be any potential for Treasury money to be used to cover any scheme costs; the scheme should be administered by a body that is not the Treasury, similar to how the Low Carbon Contracts Company operates regarding renewable energy generation,” says the letter.

The aim of the proposed revenue certainty mechanism is to lower the risk of new SAF production projects in the UK by guaranteeing investors a degree of price predictability. The government expects to complete a short consultation process in the first half of 2024, with a view to drafting new legislation and then delivery of the scheme by the end of 2026.

Photo: The UK government helped fund the Virgin Atlantic 100% SAF flight in November 2023

Christopher Surgenor

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