Jet Zero consultation response
Stop Heathrow Expansion (SHE) Response to DfT Jet Zero Consultation
September 2021
Stop Heathrow Expansion was formed to campaign against expansion at Heathrow Airport, both in the form of runways or any increase in flights beyond the current cap. We also work to reduce both air and noise pollution from Heathrow Airport and related road traffic, as well as to preserve community life and heritage in the villages near Heathrow, and to end the repeated threats and impacts to the area arising from Heathrow operations.
We have not written an in-depth response as we are in agreement with the views put forward by other organisations such as the Aviation Environment Federation, No Third Runway Coalition and Aviation Communities Forum, as well as other community groups affected by airport/aviation operations across the UK, who have submitted responses which answer each question in the consultation.
The Jet Zero Consultation does have at least one positive proposal.
The proposal that UK domestic aviation should be net zero by 2040 is welcomed and is possibly a deliverable target. However, it appears to be a passive attempt towards decarbonising aviation since domestic flights account for just 4% of UK aviation emissions. UK domestic flights should be eliminated from schedules where an alternative train route is in operation – France passed laws in April 2021 in a similar vein and the UK should follow their lead.
The cost of flying remains inexpensive compared to other public transport, in part because of the tax regime for aviation fuel. Train operators should be encouraged to take on the aviation competition, an example this week is the announcement by Lumo who are offering all fares lower than the average price of a plane ticket for the same route.
However, the Jet Zero consultation is lacking in real substance. It promotes a “business as usual” stance in the interim. Other parts of the economy have been decarbonising whilst aviation emissions have continued to grow. The Jet Zero proposals allow aviation emissions to grow until 2030 and then reduce thereafter. Consumers are being asked to make very expensive life changes to reduce their carbon footprint – such as changing their vehicles and their household heating – it is not an equitable solution. Only 15% of the population take 75% of flights and ordinary people, those who cannot afford to fly, will be paying for aviation emissions even though they will not be contributing to those emissions.
The CCC recommended demand management within the next decade to reduce aviation emissions; however, the Jet Zero proposals do not include any that might manage demand. Demand management, including aviation taxes and a frequent flyer levy, should be part of the Jet Zero package.
The Jet Zero consultation is loaded with “ifs, buts and maybes”; there is no guaranteed route to reaching Jet Zero without reducing the demand for flying. Too much emphasis is put on technologies – both in aircraft designs and sustainable fuels – that are not yet available or are in their infancy, and it is not certain if they can be available and sufficiently scaled-up in the time allowed.
We do not agree with the proposal to review Jet Zero every 5 years. The Government must keep this under review annually. A review only every 5 years would not allow Government policy to change if the technologies are not developed and emissions either remain higher for longer or, as would most likely be the case, continue to grow.
Heathrow is the single largest polluter in the UK, and its emissions account for over half of all UK aviation emissions. It currently emits around 20MtCO2 of carbon annually. A 3rd runway would increase this by approximately 7MtCO2 to 27MtCO2.
In light of the announcement on 6th September 2021 that a review of the Airports National Policy Statement is not appropriate at this time, it is our view that the Government should initiate a review of the Airports National Policy Statement once its plans for Jet Zero emissions are announced in late 2021. A review of the ANPS mustbe a review of all airports across the UK and not limited to just those in the South East.
The Government has adopted the recommendations of its Climate Change Committee (CCC) on carbon targets and, as the Queen’s Speech confirmed on 11th May, these are to be enshrined into law.
The Government committed to reducing carbon emissions by 78% (against 1990 levels) in advance of 2035 and it is demanding that, for the very first time, aviation emissions are included within targets for reductions.
As the CCC stated, this means that there is no room for a net expansion of UK aviation, and were there to be an expansion of aviation at Heathrow this would need to be offset by restrictions at regional airports (whether through reductions in operations or closures).
The UK has clear and binding targets, any net increase in airport capacity will render these targets unattainable.
The expansion of Heathrow is incompatible with the UK’s net zero targets.
It is therefore essential to stop expansion at Heathrow with immediate effect.