Response to Zero Emission Airports consultation
Here’s our response to the Zero Emission Airports consultation. We did not respond in great detail but we offered our opinions on the definition of airport operations for the purposes of the target, the emission sources within the scope of the target, how to ensure the target is implemented, and measuring and reporting of emissions. You can read our response below.
2040 zero emissions airport target
Introduction
Thank you for responding to our consultation on the 2040 zero emissions airport target.
Closing date is 2 May 2023.
View all the questions
A full copy of the questions is available here.
Confidentiality and data protection
The Department for Transport (DfT) is carrying out this call for evidence to gather further evidence on our approach to meet our ambition of airport operations in England to be zero emissions by 2040. View our DfT online form and survey privacy notice for more information on how your personal data is processed in relation to this survey.
In addition to the information outlined in the privacy notice, in order to ascertain your relationship with the topic we ask from:
· individuals, their association with aviation
· organisations, the type of organisation you are
Personal Details
Your (used for contact purposes only):
name?
Rob Barnstone
email?
rob@stopheathrowexpansion.co.uk
Are you responding:
☐
as an individual?
X
on behalf of an organisation? (Go to ‘Organisation details’)?
Individual details
3. You:
☐
reside near an airport?
☐
are a member of an aviation trade association?
☐
work in an airport?
☐
are another type of individual?
Organisation details
Your organisation name is?
Stop Heathrow Expansion
Your organisation is:
☐
an airport?
☐
a consultancy?
☐
a service provider?
☐
a non-government organisation?
☐
a manufacturer?
☐
another type of organisation?
Campaign Organisation
www.stopheathrowexpansion.co.uk
Consultation
Our ambition is for airport operations in England to be zero emission by 2040. We are gathering information to help design the policy to reach this target.
We are using this call for evidence to gather feedback on the:
· definition of airport operations
· emissions sources that should be included within the target
We want to better understand:
· to which entities the target should apply
· the type and size of airport the target should be applied to
· potential regulatory or voluntary approaches that could be used to implement the target
· how the proposed target could be aligned with current schemes, such as the Airports Council International Airport Carbon Accreditation scheme
· the barriers and opportunities which may exist in implementing the target, including commercial feasibility
· what the appropriate measuring and reporting processes should be
Defining airport operations
For the purposes of this target for zero emission airports by 2040, we believe airport operations to broadly consist of land, buildings, vehicles, facilities, equipment, and other structures used for the:
· landing and taking off of aircraft at the aerodrome, including those used for air traffic services
· manoeuvring, parking, refuelling, or servicing of aircraft between landing and take-off at the airport
· transport and processing of persons, baggage, and cargo between their arrival at the airport and their departure, including the passenger terminal
1. Do you agree or disagree with the proposed definition of airport operations for the target?
☐
Agree
☐
Disagree
☐
Don't know
Explain your response
We mainly agree with the definition, but it must also include Scope 3 emissions accrued from indirect sources such as flights, surface access (i.e. staff and passenger travel to and from the airport) and aircraft ground movements.
2. If you disagree with the proposed definition of airport operations for the target, what do you think, if anything, should be added to the definition?
The definition must include all activity within the airport perimeter.
3. If you disagree with the proposed definition of airport operations, what do you think, if anything, should be removed from the definition?
Nothing
4. What, if any, further views do you have on the proposed definition of airport operations for the target?
Airport operations must be included within the target.
Emissions scopes
We are considering Scope 1, 2 and 3 emissions. Under the Greenhouse Gas (GHG) Protocol these scopes are defined as follows.
Scope 1
Direct Greenhouse Gas (GHG) emissions occurring from sources that are owned or controlled by the company, for example, emissions from combustion in owned or controlled boilers, furnaces, and vehicles etc.
Scope 2
Electricity indirect GHG emissions result from the generation of purchased electricity consumed by the company and brought into the organisational boundary.
Scope 3
Other indirect GHG emissions, which are generally an optional reporting category for example for an airport operator this includes aircraft movements, and surface access for airport users for example the ways in which passengers and visitors, employees and commercial traffic travel to and from an airport when they are not in an aircraft.
The emissions that are accounted for under the GHG protocol are the 6 Kyoto gases:
· carbon dioxide (CO2)
· methane (CH4)
· nitrous oxide (N2O)
· hydrofluorocarbons (HFCs)
· perfluorocarbons (PFCs)
· sulphur hexafluoride (SF6)
5. Do you agree or disagree on the target being applied for the Kyoto gases as described in the GHG Protocol?
Agree
Disagree
Don't know
Carbon dioxide (CO2)
☐ X
☐
☐
Methane (CH4)
☐ X
☐
☐
Nitrous oxide (N2O)
☐ X
☐
☐
Hydrofluorocarbons (HFCs)
☐ X
☐
☐
Perfluorocarbons (PFCs)
☐ X
☐
☐
Sulphur hexafluoride (SF6).
☐ X
☐
☐
Provide further detail if you disagree with the listing.
Emission sources in scope of the target
We believe the following list, which we have summarised, of Scope 1 and 2 emissions sources from the Airport Carbon Accreditation Scheme is indicative of those that would fall within the broad definition of airport operations. These are:
· stationary sources of boilers, furnaces, burners, turbines, heaters, incinerators, engines, firefighting exercises, flares, generators and more
· mobile sources of vehicles owned by the airport (airside and landside) - trucks, employee buses, ground power units, construction vehicles and plant and more
· process emissions of onsite waste management, wastewater management
· other emissions of refrigerant losses, de-icing substances, leaks from plant particularly fire suppression CO2, fuel tanks and more
· energy indirect emissions of emissions from purchased electricity, heating, cooling and more
6. Do you agree or disagree with the list of Scope 1 and 2 emissions sources for airport operations?
☐ X
Agree
☐
Disagree
☐
Don't know
Explain your response
We agree with the Scope 1 and 2 emissions sources for airport operations provided all airport activities are considered.
7. If you disagree with the list of Scope 1 and 2 emissions sources for airport operations, what, if anything, should be added to the list?
8. If you disagree with the list of Scope 1 and 2 emissions sources for airport operations, what, if anything, should be removed from the list?
Nothing
9. What, if any, further views do you have on the list of Scope 1 and 2 emissions sources for airport operations?
Our initial view is that emissions from construction of airport buildings should not be included in this target. In addition, we do not consider necessary repairs to buildings, structures, and surfaces to be included within this target.
However, we do consider non-road mobile machinery that is used for construction purposes in relation to any building owned or operated by the airport operator to be within scope. This also excludes any emissions associated with the access of on-road vehicles to the airport site.
10. What are your views on our current approach to:
construction under this target?
Disagree. Emissions accrued from construction must be included within the target. Impacts of construction have an effect on the operations (and capacity) of the airport, so it would be wrong not to include these within the target. It is not clear how these emissions would be accounted for were they not to be included within the target.
construction vehicles under this target?
Like the previous answer, emissions from vehicles associated with construction must be included within the target.
We believe the following list of summarised Scope 3 emissions sources from the Airport Carbon Accreditation Scheme is indicative of the Scope 3 emissions sources that would fall within the broad definition of airport operations. These are:
· aircraft emissions of aircraft ground movements, engine start up to idle (run ups), engine reverse thrust, taxiing, auxiliary power unit (APU), pre-conditioned air systems (PCA), take off, landing, approach, climb, cruise from origin to destination and so on
· stationary sources emissions of third-party boilers, furnaces, burners, turbines, heaters, incinerators, engines and so on
· mobile sources emissions of ground support equipment (GSE) and ground power units operated by third parties, staff travel and commuting, haulage, business travel (third parties), land or maritime surface access (passengers), third party owned vehicles and so on
· process emissions of offsite management and disposal of airport waste, management of waste where disposal arrangements are made by third parties and so on
· infrastructure emission of grid power and fuel consumed by close partners and other third parties and so on
· other area emissions (where they are not solely controlled by the airport operator) including refrigerant losses, de-icing substances, leaks from plant particularly fire suppression CO2, fuel tanks and so on
11. Do you agree or disagree with the list of Scope 3 emissions sources for airport operations (we ask you answer regardless of whether these sources are within scope for the target)?
☐ X
Agree
☐
Disagree
☐
Don't know
Explain your response
12. If you disagree with the list of Scope e emissions sources for airport operations, what, if anything, should be added to the list?
13. If you disagree with the list of Scope 3 emissions sources for airport operations, what, if anything, should be removed from the list?
Nothing
14. What, if any, further views do you have on the list of Scope 3 emissions sources for airport operations?
The Airport Carbon Accreditation (ACA) scheme was established by Airports Council International [ACI] in 2009 and is the only institutionally endorsed, global carbon management certification programme for airports. It independently assesses and recognises the efforts of airports to manage and reduce their carbon emissions across 6 levels, with each level representing additional requirements. These are:
· level 1, mapping to determine emissions sources within operational boundaries, calculation of annual emissions, and compilation of carbon footprint report
· level 2, reduction with evidence of effective carbon management procedures and quantified emissions reductions
· level 3, optimisation with a widened scope of carbon footprint to and engagement of third-party emitters
· level 3+, neutrality using offsets for remaining emissions over which the airport has control with high quality carbon offsets
· level 4, transformation to include definition of a long-term carbon management strategy orientated towards absolute emissions reductions, aligned with objectives of the Paris Agreement. Plus, evidence of actively driving third parties towards delivering emissions reductions
· level 4+, transition with offset of residual carbon emissions over which the airport has control, using internationally recognised offsets
As part of the requirement for level 4 and 4+ of the ACI ACA scheme airport operators must report on selected Scope 3 emissions, as well as being encouraged to voluntarily include Scope 3 emissions within their targets. It is stipulated that for the latter this should include either landing and take-off (LTO) aircraft emissions or one or more sources representing more than 10% of total Scope 1,2,3 emissions (excluding LTO and cruise phase emissions) and over which the airport exercises significant influence.
15. Do you agree or disagree, that a requirement should be included as part of the target for airport operators to report their Scope 3 emissions in line with ACI requirements at levels 4 and 4+?
☐X
Agree
☐
Disagree
☐
Don't know
Explain your response
16. Do you agree or disagree that a requirement should be included as part of our target for airport operators, to ensure those emissions sources, not under operators’ direct control, are zero emission by 2040?
☐X
Agree
☐
Disagree
☐
Don't know
Explain your response
Exemptions from the target
In considering what emissions sources are in our scope, we need to consider whether specific emissions sources could be exempt from being covered by the target, for example if they are rarely used, or produce a negligible amount of emissions.
There could be multiple ways to tackle this including:
· establishing a definition of ‘regular’ airport operations, for example, the day-to-day operations required to ensure the operations of aircraft can take place. Conversely, ‘irregular’ or ‘special’ operations would cover more unpredictable events such as severe weather requiring the use of a snow plough or a power outage requiring backup generation, as well as activities required on safety grounds like fire training
· setting a minimum threshold of emissions for inclusion in the target. For example, if an activity accounted for less than 0.5% of total airport operation emissions, it could be excluded
· individual activities that could be listed as exempt based on a case-by-case assessment
17. How should any potential exemptions from the target be dealt with?
☐
Definition based on regular and irregular activities
☐X
Minimum threshold on emissions
☐
Individual activity exclusion
☐
Other:
Explain your response.
Entities subject to the target
For the purposes of this target for zero emission airports by 2040, we believe airport operations to broadly consist of land, buildings, vehicles, facilities, equipment, and other structures used for the:
· landing and taking off of aircraft at the aerodrome, including those used for air traffic services
· manoeuvring, parking, refuelling, or servicing of aircraft between landing and take-off at the airport
· transport and processing of persons, baggage, and cargo between their arrival at the airport and their departure, including the passenger terminal
18. Do you agree or disagree, that the target should be applied to other entities whose Scope 1 and 2 emissions fall under the definition of airport operations?
☐ X
Agree
☐
Disagree
☐
Don't know
Explain your response.
In considering which entity is responsible for different emissions sources, it is important that the appropriate method is used. The Greenhouse Gas (GHG) Protocol sets out 2 distinct approaches to measure this.
The first is an ‘equity approach’, which is where a company accounts for GHG emissions from operations according to its share of equity in the operation (usually the same as the ownership percentage).
The second is the ‘control approach’ where a company accounts for 100% of the GHG emissions from operations over which it has control and has two further subdivisions of:
· financial control
· operational control
The approach advised to be taken as part of the ACI ACA, and stakeholder feedback is the ‘operational control’ sub-division method of the ‘control approach’. This approach works on the basis that an airport accounts for 100% of emissions from operations where it has the full authority to introduce and implement its operating policies.
19. Do you agree or disagree that the operational control approach should be used to apportion responsibility for airport operation emissions under the target?
☐
Agree
☐
Disagree
☐
Don't know
Explain your response.
If you disagree, which alternative approach would you prefer?
Airports subject to the target
Operations can vary considerably depending on size and type of airport. By size of airport, we refer to the number of passengers per annum (measured in millions of passengers per annum [mppa]). However, there are also other ways to measure the size of an airport, which will also bring into account a wider range of business operations. For example, there are several airports which do not operate a significant number of commercial passenger flights but do operate a significant number of other operations such as freight or business flights, which may be more accurately measured in air traffic movements.
It was found that large airports (above 25mppa) have the greatest feasibility to decarbonise, driven by greater market power. However, medium sized (5 to 15mppa) and small sized (less than 5mppa) airports may benefit from being required to transition a smaller number of assets. There are also variations between the regulatory regimes of these airports.
20. Do you agree or disagree that there should be a minimum threshold based on the size of the airport, below which the target does not apply?
☐
Agree
☐
Disagree
☐
Don't know
Explain your response.
21. Which metric should be used to determine an airport's size?
☐ X
Passenger numbers
☐ X
Air traffic movements
☐
Another metric:
Explain your response.
22. Which types of airport business operations should the target apply to?
☐X
Commercial passenger
☐X
Freight
☐X
Private
☐
Other:
Explain your response.
How to ensure the target is implemented
23. What policy option do you think is most appropriate for the implementation of the target?
☐X
Legislative requirement
☐
Voluntary agreement
☐
Commitment by each airport to produce a roadmap
☐
Other:
Explain your response.
24. What are your views on a voluntary approach to implement the target?
Voluntary approaches to decarbonising have a poor record in the aviation industry, in particular at large airports such as Heathrow.
25. If there is a voluntary approach for this target, what should it look like, and how should it ensure the target remains robust and is delivered?
26. Do you agree, or disagree, that there should be a penalty for non-compliance with the target?
☐
Agree
☐
Disagree
☐
Don't know
Explain your response.
27. If there is a penalty for non-compliance, what should this look like?
Restrictions in operations such as a limits on the number of ATMs as well as financial penalties such as a fine(s).
28. What, if any, specific issues do you anticipate with the target only being applied to airports in England if similar targets are not applied by devolved administrations?
Barriers to implementation
Whatever policy approach is taken to implement our target, there are several barriers to be considered. One of the key barriers cited in the Jet Zero consultation responses was the commercial feasibility of the target and the need for sufficient financing. While the Mott MacDonald feasibility study concluded that commercial feasibility for decarbonisation is viable for the majority of airports, it recognised that there will be a variety of commercial and financial challenges in this transition, which will likely include the:
· affordability of decarbonisation measures and the potential need to adapt or replace technologies or infrastructure before the completion of their whole lifecycle
· availability of finance, especially post COVID-19 where revenues may not be available to cover changes needed
· impact of regulatory or passenger charges models for airports and the capacity in these systems to allow for change management
29. What do you think are the main barriers in implementing the target?
☐
Other regulations
☐
Safety issues
☐
Operational issues
☐
Commercial viability
☐
Skills/capability gaps
☐
Investment in technological developments.
☐ X
Other:
Explain your response.
Lack of willingness in the aviation industry.
30. Do you have an approximation of the scale of investment required to achieve this target?
☐
Yes
☐
No
☐
Don’t Know
If so, provide any details you have including references to data sources.
31. What financial government initiatives would help to achieve this target?
32. What non-financial government initiatives would help to achieve this target?
Opportunities for implementation
Implementation of this target could provide co-benefits in facilitating the transition to hydrogen aircraft fuelling by generating demand and developing hydrogen handling, storage, and transportation technologies in the airport ahead of the aircraft technology for this fuel being readily available.
There may also be benefits for the airports and supply chain companies taking a leading global role in developing zero emissions airport technologies. This may increase growth and export potential and provide market opportunities globally for UK expertise in decarbonising airports, which could help incentivise further development of our supply chain to provide necessary goods and services for zero-emission airports.
33. What, if any, opportunities do you think exist that could be exploited in the implementation of the target?
34. What technologies are important to achieve this target?
35. Are current government policies sufficient to encourage transition to these technologies?
☐
Yes
☐
No
☐
Don't know
Explain your response.
36. How could the implementation of this target help to support the future shift of airports to integrate hydrogen?
37. How, in your view, should airports look to develop export potential in regard to their transition to zero emission operations?
☐
Via supply chain capability
☐
Via research and knowledge capability
☐
Via new technologies
☐
Via other ways:
Explain your response.
Measuring and reporting of emissions
38. What ideas, if any, do you have for how a progress reporting requirement could operate?
All reporting must be independently verified and publicly available.
39. How frequently should progress towards the target be reported?
Twice annually
40. What are the metrics that you think progress should be measured against?
41. Do you agree or disagree, that there should be a defined standard that should be followed by the entities covered by the target to allow for effective monitoring of progress towards the target?
☐
Agree
☐
Disagree
☐
Don't know
Explain your response.
42. What are, if any, the specific issues you anticipate with regards to increased emissions reporting?
Further comments
43. Is there anything else we have not considered that is relevant to this target?
44. Any other comments?