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Friday, August 03, 2007

Correspondence with the new Minister for Aviation, Jim Fitzpatrick

The correspondence below is Jim Firtpatrick's reply to the previous letter that was sent to Gillian Merrron (his predecessor) and my subsequent reply. The basic synopsis is that the Ministry for aviation still has no evidence to quantify the environmental damage that their proposed airport expansion is likely to inflict. It reinforces the view that they appear intent on pushing forward the developments against all the mounting environmental evidence of dangerous climate change and are not able to provide event the slightest credible argument as to how the environmental damage can be reduced.

Further to this, the uncertainty of such a weak argument is damaging to the share holders of BAA who have been unable to refinance their debt. see the article in today's Telegraph.

Again, I must thank my MP, David Drew, for his persistence and efforts in helping to clarify the government's position and test the strength of their arguments.


My reply to Jim Fitzpatrick's Letter.

David Drew MP
House of Commons,

2 August 2007

Dear David,

Thank you for pursuing my latest letter to the minister of Aviation and please do thank Mr. Fitzpatrick for his reply.

I do however take issue with his comments and it would appear from his response that he has not thought through the implications of some of the facts and figures that he is quoting.

Mr Fitzpatrick has stated that the industry seeks to improve fuel efficiency by 50% on new planes. The Sustainable Development Initiative does not quote 50% for new aircraft, as 5-10% of the 50% improvement is based on improved air traffic management. Thus, it is reasonable to assume that the industry only expects new aircraft to achieve a 40% improvement in efficiency.

More concerning is the statement in the 2003 report “The Future of Air Transport” (ref Chapter 3 on the Environmental Impact of Aviation) where it states “Research targets agreed by the Advisory Council for Aeronautical Research in Europe suggest that a 50 per cent reduction in CO2 production by 2020 can be achieved.” This document formed the basis of the airport expansion strategy’s position on climate change. There is no reference what so ever about the 50% relating only to new aircraft. The reference to new aircraft was changed in the progress report of 2006 where it states “a target to improve fuel efficiency by 50 per cent per seat kilometre in new aircraft in 2020 compared to 2000.” This is a very much less demanding criterion than was initially stated in the original paper. There is no evidence that this reduction in aspiration was challenged or that the environmental impact been reassessed in light of this fundamental change.

Furthermore the government’s central and best-case scenarios assume that the 50% target efficiencies are achieved. However, the Aviation and Global Warming report, to which Mr. Fitzpatrick refers, states in no uncertain terms how difficult it will be to achieve these targets. The report states, “Full achievement of the targets will require the employment of novel concepts and breakthrough technologies into commercial service.” Given this, one would assume that there is a high risk that the targeted efficiency improvements will not materialise due to unforeseen technical issues. For example, serious questions are being asked about lightening protection with the new Boeing 787. Also, the report highlights that efficiency in engines is now at a virtual optimum and that making CO2 emissions improvements will be a the expense of higher NOx emissions, which is an extremely aggressive greenhouse gas. Thus the words “best-case scenario” could equally be replaced with “least likely scenario.”

Furthermore Mr. Fitzpatrick confirms that the 50 per cent efficiency target is an industry target and not a government target. This implies that if the industry does not achieve the publicised targets, then the government will take no action. Could Mr. Fitzpatrick confirm that this is in fact the case?

Critically, as established with Mr Fitzpatrick’s predecessor, the industry does not capture total CO2 emissions per passenger. So whilst the new generation of planes will be more efficient, the reduction in CO2 emissions per km is being wiped out by the longer haul nature of the journeys. This lack of critical data also suggests that it is difficult to have any meaningful discussion on future CO2 emissions from aviation. It is also violates the commitments made in the Future of Aviation document and the subsequent progress report which both committed to improving the data on aviation emissions.

Mr Fitzpartick states that domestic flights only account for 0.4% of UK emissions. This does not relate to the figures from the Environmental Audit Committee and clearly does not take account of additional radiative forcing, or future growth. Furthermore, international travel contributes by far the most emissions and the airport expansion in this country is targeted at supporting international travel.

I have repeatedly asked what progress has been made in getting the aviation industry incorporated into a Carbon Trading mechanism and what timetables we can expect as this is the lynch pin of the government’s policy. I note that Mr. Fitzpatrick says “The Future of Air Transport document highlights that emissions can be managed through a well-designed, international emissions trading scheme and that the International Civil Aviation Organisation has been leading this, but progress is slow.” Slow progress is hardly a surprise. The world does not have any well-designed, international trading schemes for any carbon emissions. It would be helpful if Mr. Fitzpatrick could articulate exactly what he means by a well-designed, international emissions trading scheme. As existing carbon trading schemes have been so contentious, it is no surprise that something as difficult as civil aviation is finding it hard to come up with one. Furthermore, if this is being lead by the Civil Aviation Organisation, then slow progress can only be expected due to the inherently vested interests of an organisation such as this.

Mr. Fitzpatrick goes on to say “Under the arrangements currently proposed by the European Commission, any increases in carbon emissions from flights departing from or arriving at EU airports would need to be offset by emission reductions made elsewhere in the economy.” This clearly depends on suitably robust CO2 emissions targets that force cuts elsewhere in the economy. Could Mr. Fitzpatrick confirm that any current targets or aspiration for targets will not simply be increased to accommodate the full global warming impact of aviation and avoid the necessary cuts having to be made elsewhere in the economy? The footnote on page 28 of the Draft Climate Change bill suggests that if aviation were incorporated into a carbon-trading scheme the CO2 emissions targets would be increase to accommodate it? Furthermore, could Mr. Fitzpatrick confirm that if cuts cannot be made elsewhere in the economy, would the government curtail additional growth in the aviation industry?

Mr. Fitpatrick also says “emissions trading allows the market to determine where the most effective emissions reductions can be made.” It is rather worrying that Mr. Firtpatrick seems only intent on articulating the end goal rather than thinking through how it would be achieved, how feasible it is to expect the market to deliver the cuts, and what timetable of carbon reductions would subsequently follow. Could Mr Fitzpatrick explain if any analysis has actually been carried out on the markets ability to accommodate the full impact of aviation’s contribution to global warming and what risks are foreseen? I would also appreciate a copy of any analysis that has been completed under the freedom of information act.

If there is no evidence to satisfactorily answers these questions, does Mr. Fitzpatrick agree that in light of the extreme risks of run away global warming, that we should be adopting a precautionary principle and not allowing any further development of the aviation industry until we understand exactly what total emissions improvements will be achieved from operational aircraft and what levels of carbon can be offset through the proposed trading mechanisms.

Yours truly

Kevin Lister, Bsc(eng) hons, MBA


Jim Fitpatricks Letter (to David Drew MP)

Thank you for your letter of 18 June to my predecessor enclosing further correspondence from your constituent Mr Kevin Lister of Brooklyn, Park Road Crescent, Nailsworth, Stroud, regarding aviation and the environment. This letter set out a number of points which I have attempted to address in turn below.

The target to improve fuel efficiency by 50% by 2020 referred to in previous correspondence is a target that has been adopted by the aviation industry's Sustainable Development Initiative and is not a Government target. It is a target that measures improvements in fuel efficiency in new aircraft entering the fleet and not aggregate fuel efficiency to which the graph in your letter refers.

In our published CO2 forecasts, we presented three scenarios - central, best and worst case - reflecting different assumptions on aspects such as economic instruments and fuel efficiency. Both our central and best case scenarios assume that the target mentioned above for new aircraft has filtered through such that the whole fleet has improved its fuel efficiency by 50% by 2050 (i.e. it is assumed that in that longer time frame, fleet turnover will have made the whole fleet more efficient). Further information can be found in the DfT publication Aviation and Global Warming: warmingreport.

Emissions from international aviation and shipping are not included in the targets of the Climate Change Bill as there is currently no agreement on how to allocate these international emissions to national inventories.

The Bill does however cover CO2 emissions from domestic flights which currently account for 0.4% of UK CO2 emissions.

The UK Government is not discounting or ignoring these international emissions, and in fact we do report on international aviation emissions in our national inventory as a memo item, along with emissions from international shipping. The fact that emissions from international aviation and shipping are not included in the draft Climate Change Bill does not mean that we are not taking action to tackle the climate change impacts of aviation.

On the contrary, the Future of Air Transport White Paper sets out our commitment to ensuring that aviation reflects the full costs of its climate change emissions and highlights that the most efficient way of doing this is through a well-designed, international emissions trading scheme. As a result, the UK has been and continues to press for the development and implementation of such a regime through the International Civil Aviation Organisation (ICAO). However, progress to date at this level has been slow so in the meantime we have worked towards the extension of the EU emissions trading scheme to include aviation. In December 2006, the Commission published its draft proposal and since then the UK has been actively participating in negotiations to ensure that aviation is incorporated into the scheme as soon as possible.

Under the arrangements currently proposed by the European Commission, any increases in carbon emissions from flights departing from or arriving at EU airports would need to be offset by emission reductions made elsewhere in the economy. The Commission's impact assessment estimates that this proposed scheme could reduce aviation emissions by up to 183MtC annually by 2020.

Mr Lister asks about how a reduction in aviation emissions will take place and what impact this will have on other sectors bound by emissions reductions targets. We believe that by establishing a market price for carbon, emissions trading encourages efficient behaviours which reflects the demand for carbon across the whole economy. So rather than making industry-specific carbon targets, which would be arbitrary and inflexible, emissions trading allows the market to determine where the most effective emissions reductions can be made, allowing those companies who innovate to benefit and those who find it more difficult to contribute by funding reductions made elsewhere. This approach was endorsed by Sir Nicholas Stern's report on the economics of climate change, which strongly supports carbon pricing as a means of ensuring that economic decisions fully reflect social and environmental costs.

The Government has been very active in engaging with industry throughout the development of both the Future of Air Transport white paper and the draft Directive on including aviation the emissions trading scheme. In fact, the joint DfT and Defra consultation on emissions trading recently closed and involved extensive discussions with airlines, wider industry, NGOs and other interested parties. The views and information provided through the consultation will feed into the policy development in the coming months to ensure that aviation is included in the EU emissions trading scheme in the most environmentally effective way.

hope you find this information useful.

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