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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A report by low carbon energy consultants Element Energy (EE) analysing the UK government’s ‘Jet Zero’ strategy to hit net zero aviation emissions by 2050, with interim reduction targets for the 2030s, concludes the scenarios are over-optimistic. The report, commissioned by UK campaign group the Aviation Environment Federation, concludes acting early by halting airport capacity growth along with implementing other demand reduction measures pose a far less risky approach to reaching the targets. EE estimates the aviation sector will need to cut emissions faster and deeper in the near term than the government is currently projecting. The government’s plans overestimate the likely improvements in operations, technology and alternative fuels, along with out-of-sector solutions such as engineered GHG removals, and are unlikely to be developed at the speed and scale necessary, it argues. AEF, meanwhile, has joined with other NGOs in calling on the government to withdraw its policy support for UK airport expansion until aviation emissions start falling and wider emissions are “substantially below” a 1.5°C-compliant trajectory.

Despite aviation demand – in terms of UK terminal passengers – being forecast to increase by over 70% in the latest government assumptions between 2018 and 2050 under its High Ambition scenario, aviation is expected to be one of only two sectors (the other being agriculture) still to have residual emissions in 2050, with very high-cost carbon removals required to mitigate this. As laid out in its Jet Zero further technical consultation in March 2022, possible trajectories by the UK Department for Transport (DfT) show in-sector CO2e emissions of 36Mt in 2030, 28Mt in 2040 and 15Mt in 2050, or net CO2e emissions of 24-29Mt in 2030, 12-17Mt in 2040 and 0Mt in 2050. The latest government statistics show international aviation emissions in pre-pandemic 2019 amounted to 37MtCO2e, which have more than doubled since 1990, with a further 1.5MtCO2e from domestic flights.

As part of its net zero by 2050 commitment, the UK aviation industry last year announced interim decarbonisation targets of a net reduction in emissions by “at least” 15% by 2030, relative to 2019, and a 40% net reduction by 2040 as, said its Sustainable Aviation cross-sector alliance, “with the pace of decarbonisation ramping up as game-changing sustainable aviation fuels, permanent carbon removal, and new low and zero-carbon technologies – such as electric and hydrogen-powered aircraft – become mainstream in the 2030s.”

However, the report by Element Energy says the High Ambition scenario “is over-reliant on emerging high-risk technologies and uncertain policy in the forecasting of the emission abatements in 2035.” Key risk factors, it says, include a slow-down in aerospace R&D spend post-Covid that makes it unlikely efficiency improvements will achieve a step-change growth of 2.0% annually from 1.5% historic levels. It is also pessimistic about the higher levels of SAF demand required by 2035 to meet the High Ambition scenario and questions as misleading the 100% emissions savings assumed from SAF. In addition, it criticises the exclusion of aviation non-CO2 effects as substantially underestimating aviation’s warming impact.

It also says the scenario sees a substantial emissions abatement in 2050 relying on CORSIA carbon pricing on long-haul flights reaching ETS levels, which it believes is unlikely. CORSIA, ICAO’s global carbon offsetting scheme for international aviation, is currently designed to end in 2035.

“Overall, it is unclear how DfT plans to deliver these high rates of technological improvements, SAF uptake and aircraft efficiencies,” says the report. “Expanding carbon pricing, with EE estimations suggesting that only about 17% of total aviation emissions are currently priced, would also be essential to support the rapid uptake of new technologies by airlines but would rely on breakthroughs at ICAO in terms of the level of ambition in CORSIA and future arrangements for a market-based measure after 2035.”

EE says relying on greenhouse gas removals is also risky and argues “they should only be deployed once both technological and behaviour change options to reduce emissions have been exhausted.”

It suggests demand management policies could take several forms, including reducing passenger demand for flying through carbon pricing, an air miles or frequent flyer levy, applying VAT or reforms to Air Passenger Duty, and restricting the availability of flights through management of airport capacity. Additional non-financial behaviour change interventions could include improved marketing of domestic tourism opportunities and consumer information about the CO2 impacts of flights.

“Constraining demand now through airport capacity is far easier and more reliable than allowing capacity and demand to grow and then rapidly trying to reduce demand in the future through pricing mechanisms,” says EE. “We conclude that there should be no airport expansion until and unless it is clear that both in-sector (aircraft technology) and out-of-sector (carbon removal) emissions reductions are on track to meet a fair emissions reduction for 2035 and beyond.”

Commenting on the findings, Cait Hewitt, Policy Director at the Aviation Environment Federation, said: “The government’s plan is to sit back and allow both airports and emissions to grow in the short term while hoping for future technologies and fuels to save the day. This new report gives a damning appraisal of the level of risk in every aspect of the current approach to aviation emissions and highlights the need for action now, including ruling out airport expansion and limiting demand, to ensure aviation makes a fair contribution to cutting emissions by 2035 and is on a pathway to net zero by 2050.”

On the back of the report, AEF and six other environmental NGOS – AirportWatch, Friends of the Earth, Green Alliance, Greenpeace, Possible and Transport & Environment – have written an open letter to Aviation Minister Robert Court that calls on the government to withdraw its support for airport expansion in the UK. The letter also expresses concern over the assumptions the government’s Jet Zero draft strategy makes on increases in sustainable fuels and carbon removals occurring after 2030, “but with no clear policy plan to ensure they are delivered.”

Photo: Heathrow Airport