We responded to the call for evidence from the inquiry on 24th April 2025:
Recent airport planning inquiries to date have been unable to assess the individual impact of a specific airport expansion or the cumulative impact of UK-wide airport expansions vs. an airport-specific carbon budget or a UK-wide aviation carbon budget, as these do not exist.
As such, our main recommendation would be for the creation of a UK aviation carbon budget, and for this to be subdivided (based on political choices on levelling-up and access to air travel) into airport-specific carbon budgets which can then be used to assess airports on an individual basis to ensure that the combined, cumulative emissions from all airports will not exceed the national UK-wide budget.
It’s worth noting that such a budget would not necessarily prevent airport expansion or air traffic growth, as this could then be achieved if aviation companies are able to scale the technologies and fuels as predicted.
Before an airport expansion is approved, the following conditions could be set:
● It must stick to an agreed carbon budget
● It must only use the latest generation aircraft with the highest fuel efficiency and lowest noise ratings.
● It must implement a gold standard of operations to reduce air pollution.
● It must meet a certain percentage of flights via zero-carbon aircraft.
The following arrangements could be made to keep airports and aviation policy under review to ensure that climate and environment obligations continue to be met:
● Every year review and report:
- UK aviation emissions
- “SAF” scale-up and the effectiveness of “SAF” in reducing the overall carbon intensity of aviation.
● Every three years: review the UK aviation industry / Jet Zero strategy
- Utilise Aviation Workers’ Assemblies to provide democratic worker expertise and insight into policy recommendations.
The following policy safeguards could be offered by Ministers to ensure that the climate and environmental impacts from domestic and international aviation continue to be mitigated in a way consistent with these obligations:
● Carbon Budget for UK Aviation: sub-divided to individual UK airports.
● Aviation-specific ETS: separate aviation emissions from other sectors, and apply a different carbon price for flights vs. the ETS price for other sectors. This would allow improved price control over aviation without impacting other sectors.
● Carbon price for non-ETS flights: covering the portion of emissions under CORSIA which are not currently priced by the CORSIA scheme.
● Upgrade UK Air Passenger Duty (APD) to improve control of CO2 emissions by increasing the number of distance bands, increasing the rate for premium seats and private jet flights and increasing the rate for less fuel efficient aircraft.
● Regulate ‘frequent flyer programmes’ / ‘air miles schemes’: e.g. apply a specific tax to the revenue generated from these programmes / schemes.
● Frequent Flyer Levy:
● Zero Emissions Flight (ZEF) mandate for new airport runways/terminals:
- We have written about this recently related to Luton Airport: https://safe-landing.org/luton-airport-expansion-apr-2025
- If a second runway is opened at Gatwick, we think this should be for zero-carbon aircraft only: https://safe-landing.org/gatwick-expansion-feb-2025
- As these aircraft will initially have very different range and payload (passengers/cargo) compared to conventional aircraft, they will require a fundamentally different air transport network and airport runway, terminal, gate and recharging or refuelling infrastructure. As such, we see a key role for regional and private jet airports to be the initial sites for early “ZEF” operations. For instance: London City Airport, Biggin Hill, Oxford and Farnborough Airport around London: https://safe-landing.org/farnborough-airport-expansion-consultation
● Contrail avoidance: urgent policy action to mitigate contrail warming: https://safe-landing.org/contrail-avoidance-study