Transition to low and zero emission aviation

The first section of the consultation discussion document sought views on reducing the environmental impact of aviation, in line with the Scottish Government’s commitment to be a net-zero nation by 2045 and for Scotland to benefit economically from the transition to low and zero emission aviation.

Q1. What more, if anything, should the Scottish Government and industry do to accelerate the transition to low/zero emission aviation?

Research, Development and Infrastructure Support

The main theme to emerge in response to this question was support for the development of more efficient, as well as low and zero emission, aircraft. Both workshop participants and online respondents urged research and investment into alternative technology, including electric and hydrogen flights and sustainable aviation fuels (SAF). Workshop participants stressed the importance of both private and public sector investment in order to bring these new types of aircraft to market.

Among organisations in particular, investment in technology (and its testing) emerged as a strong theme, as well as the development of SAF at scale:

There must be massive investment in new technologies to produce and use sustainable liquid aviation fuels (SAF), or electricity. Even designing and building this new infrastructure and (at least in the case of electricity) aircraft will have its own substantial carbon footprint which must be accounted for.”
(Individual)

Investment in aerospace engineering and modernisation was also encouraged by several, as well as investment in infrastructure for aviation. Piloting/trials of zero emission flights on some domestic routes was also urged.

Encouraging greater use of electric and hydrogen flights (especially for short haul) and more Scottish Government investment in testing of electric and hydrogen aviation was also suggested by several online respondents. Workshop participants also suggested that electric and hydrogen powered aircraft were particularly promising for the future of short haul aviation and suggested encouraging airlines to use the newest, most fuel-efficient aircraft and to upgrade their fleets. This was coupled with calls for infrastructure changes (both from online and workshop participants) to support a greater move to electricity and hydrogen. Aviation representatives suggested that the Scottish Government could support airports to put this in place:

Infrastructure will be key to new technologies that will deliver zero emission flight…the Scottish Government should engage closely with groups such as the British Aviation Group and other infrastructure providers to ensure that Scottish aviation facilities are able to support the development of electric and hydrogen aircraft. This should include a focus on charging stations, hydrogen production, refuelling and distribution capabilities, and requisite
maintenance facilities.”
(Aerospace company (including representative bodies))

While popular, others warned that use of electric aircraft alternatives was not without negative environmental impacts, and this should be factored into any strategy (i.e. increased electricity demand must be met with plans for renewable electricity generation and, as with electric land vehicles, the manufacture, transport, and disposal of batteries necessary for electrically powered aircraft would need to be considered). Workshop participants concurred with online respondents that it was important to consider the whole supply chain, from production to transportation to storage, as well as the need to consider how aviation’s demand for hydrogen/renewable electricity might impact on other sectors and policy aims. Workshop participants also suggested that it was important to recognise the challenges of switching to hydrogen/electric aircraft and the fact that such aircraft would not be suitable for a lot of Scotland’s international routes.

More general comments included that more investment into research and development was needed, to explore if zero emission aviation was possible and the targets achievable, as well as into sustainable aviation fuels more generally:

The Scottish Government should consider funding research and development in low and zero emission aviation to attract businesses and research institutes and collaborate with other nations to exchange knowledge and expertise in these areas.”
(Transport Partnership)

As a caution, several respondents indicated that, whilst technological developments were welcomed across the sector, they would take time, and progress may not be achieved quickly enough to help meet the Scottish Government’s commitment to be a net-zero nation by 2045:

…it must be recognised in the Strategy that there are significant challenges to be overcome and that technology is not yet advanced enough to allow users to enjoy the social and economic benefits of air travel, while reducing the environmental impact of flying to any meaningful extent…until there are greater advances in engine and fuel technology, the aviation sector will struggle to contribute its fair share of emissions reductions to Scotland’s net zero target within the required timeframes. The Aviation Strategy must recognise this.”
(Individual)

Partnership working

Alongside research and development, several respondents also stressed that a partnership approach to developing and delivering this part of the Aviation Strategy was needed:

Achieving net zero emissions for UK aviation by 2050 will require ever stronger partnerships between Governments, the aviation industry and key low carbon innovation partners. Clear policy and leadership decisions are required today, to ensure that today’s breakthroughs in aerospace technology, sustainable aviation fuels and carbon removal are maximised.”
(Aviation and associated industries (including representative bodies))

Workshop participants agreed that the Scottish Government could play a coordinating role, to help bring together the different strands of activity in relation to low and zero emission aviation. Workshop participants also suggested that international standards could help speed up the use of new types of aircraft and one environmental NGO suggested that a government mandate on their use would also be needed.

The Scottish and UK Governments should also ensure that the right policies are in place to push for and incentivise the transition to low and zero emission aviation by the industry, it was stressed. This may include increasing taxes for unclean aviation fuel (especially on short haul flights) and reducing taxes for sustainably-powered aircraft:

Incentives need to be in place to push aviation in the correct direction. Fuel costs make up the majority of aircraft operating costs, so a move towards potentially cheaper alternatives benefits all parties - but the technology must be ready.”
(Aviation and associated industries (including representative bodies))

Demand reduction

Actively reducing demand or excess travel was stressed across a number of online individual and organisational responses, including reducing flight numbers (especially cancelling flights with low passenger numbers) and limiting the number of flights per person (possibly by introducing taxation of frequent flyers):

I suggest small aircraft routes could perhaps reduce the number of flights required by offering lower fares to passengers who are flexible with travel times and willing to accept having their flight cancelled and moved to a different day, or time of day. If a flight had only two or three passengers, and those passengers were offered a partial refund of their fares, then, if they all took up the offer, the flight could be cancelled altogether.”
(Individual)

Linked to this, several respondents stressed the need to promote alternatives to flying as the most effective way of achieving the transition to low/zero emission aviation. Several suggested decreasing the cost of travel by train or bus and/or increasing the cost of flying. More investment in alternative travel options including trains and buses to encourage more land-based travel (not only within the UK but across Europe) was also suggested:

The focus really needs to be on reducing aviation full stop, especially domestic flights. That means massive investment in railways to improve services, and dramatically reduce cost of fares to encourage people to use trains and not flights or cars within the UK.”
(Individual)

A small number of (mainly individual) respondents advocated here and elsewhere in the consultation that all air travel (except essential travel) should be banned or capped at existing levels.

Travel to and from the airport

Other online respondents (including Regional Transport Partnerships) commented that the aim of low/zero aviation emission would only be achieved if approached in the wider context of Scotland’s transport network and policy objectives to achieve net zero by 2045:

…it is imperative that aviation continues to be part of the overall transport offering providing good connectivity… and is not seen as a stand-alone method of travel. It needs to be part of an integrated transport system that together aims to decarbonise transport. Therefore, good surface access to airports by public transport, ground operations at the airport and decarbonising the flights themselves should all be considered in decarbonising air travel.”
(Transport Partnership)

One regional transport partnership suggested that the Aviation Strategy should set out the strategic direction and requirements for getting to and from airports (which although covered by the Strategic Transport Projects Review 2 (STPR2) requires separate strategic thought). The same organisation suggested that the Strategy should build on the National Transport Strategy and complement Regional and Local Transport Strategies, while others stressed that the Aviation Strategy would only be successful if considered alongside wider transport policy change:

Ensuring that airports are served by good public transport and, where applicable, active travel routes will help to reduce emissions around the aviation sector, as well as those generated directly by it.”
(Business Representative Body)

Other suggestions

Other specific suggestions to accelerate the transition to low/zero emission aviation (mentioned by just one or two respondents each) included:

increasing the environmental ambition of the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) and the UK Emissions Trading Scheme (UK ETS) to incentivise airlines to use low and zero emission aircraft.
introducing measures to end all engine idling in airports (including plane engine idling, airport buses, cars, taxis, etc.);
encouraging small aircraft to use more regional airports;
connecting up some small regional airports with overseas destinations that are comparatively close and reinstating some short haul connecting routes;
banning light aircraft unless essential and banning executive/private planes;
introducing more efficient scheduled arrivals management systems/refine scheduled aircraft arrival streaming; and
actively promoting the importance of behaviour change.

Specifically for the islands, one local authority suggested that the Scottish Government could accelerate the transition to low and zero emission aviation by continuing support in meeting the costs of air travel. This would ensure healthy demand for travel to/ from the islands which would support commercial viability of services. This in turn would also support operators in stimulating demand for net zero aircraft solutions and the pace at which they are developed.

A small number of respondents questioned the evidence and data underpinning the discussion document with perceptions that the proposed tools for achieving emission reductions would not be able to deliver the reductions that are necessary in the short and medium term. Reliance on Emissions Trading Schemes and offsetting arrangements such as CORSIA received specific criticism and some stressed that the discussion document did not go far enough in putting forward the radical proposals for change that were needed to achieve the set targets.

Q2. What can the Scottish Government do to help increase the use of sustainable aviation fuels?

Feedback on this question focussed mainly on financial solutions that the Scottish or UK Governments could adopt to encourage sustainable aviation fuels (SAF) production and use, including:

reducing cost of SAF to operators;
providing grants, loans and/or subsidies to airlines to encourage use of sustainable aviation fuels;
heavier taxing of non-sustainable fuels (and lower taxes for SAF compared to non-sustainable fuels); and
funding of more research and development into sustainable aviation fuels.

There was consensus that SAF needed to be financially attractive for airlines. Tariffs on sustainable and traditional aviation fuels needed to be transparent and easy to administer and the Scottish Government should seek to influence the UK Government to deliver, with urgency, a progressive taxation environment for the most sustainable fuels, it was suggested.

More general investment in, and promotion of, SAF and, more specifically, a desire to encourage production of SAF in Scotland, was stressed by several online respondents. This included actively working to establish manufacturing sites at suitable locations such as Aberdeenshire, Grangemouth and possibly even in Shetland using the existing pipelines to get SAF to the mainland. Several respondents said that SAF were currently cost-prohibitive and that a key priority would be reducing production costs, including by encouraging domestic production within Scotland. Workshop participants also noted the possible economic and environmental opportunities from the production of SAF in Scotland and suggested that there could be a role for government in starting this up/providing investors with the confidence to spend the large sums of money which would be needed to take this forward.

Domestic production would also mitigate the costs, environmental damage and high carbon footprint associated with importing sustainable (crop based) fuels:

It harms the environment to grow crops specifically for fuel - even more so when imported. The fuel for growing and transport is likely to exceed the final product. Imported fuel from crops often drives deforestation.”
(Individual)

There was agreement among those in the aviation industry that SAF needed to be easily available, viable and cleared for use on aircraft. It was felt that the Scottish Government could help with this by assisting in the development of an economically viable SAF infrastructure for different fuel types, and by applying pressure to aircraft and engine manufacturers to test and clear the use of such fuels on their aircraft.

Others (mainly operators) expressed concerns regarding increased costs as well as supply, and suggested that the UK government’s proposed mandated use of low blends of SAF may cause demand to outstrip supply for the foreseeable future as well as increasing costs to passengers disproportionately. Therefore, government support to enable the infrastructure and supply to deliver sufficient SAF to meet demand was encouraged:

The Scottish Government should set out a comprehensive policy framework for commercialising SAF, which in addition to financial mechanisms, must ensure the planning system is supportive of the development of SAF plants.”
(Aviation and associated industries (including representative bodies))

Scottish Government can tackle some of the commercial risks to the private sector of developing and investing in production and distribution infrastructure through supporting key projects and coordination the planning at a Scottish level.”
(Local Authority/Public Body)

Other suggestions to help increase the use of sustainable aviation fuels included:

phasing out of fossil fuels;
prioritising use of SAF for domestic flights in the short term, which is likely to be more acceptable and achievable for operators;
pricing all flights as if they were already using SAF to challenge and change expectations around the cost of flying;
mandatorily offsetting all tickets and implementing a frequent flyer levy. These views were countered, however, by those who stressed it would be important not to exclude people who rely on flying, particularly with regard to Highland and Island communities;
support to enable the development of technology to create SAF; and
increased funding for research and development of SAF.

More general comments suggested the need for very specific and measurable goals in SAF use to be set at the UK level to ensure progress is made and can be monitored:

The lack of clear, long term Government policies to support SAF production in the UK has pushed back SAF production and use… we are urging the Government to set out a comprehensive policy framework for commercialising sustainable aviation fuels, alongside finance mechanisms that will be critical to delivering first-of-a-kind UK SAF plants. Specifically, the SAF mandate needs to be implemented along with a UK price stability policy, such as contracts for difference, by the end of 2022. This is to ensure the UK realises the full potential from SAF.”
(Aviation and associated industries (including representative bodies))

A minority indicated that they were sceptical about the aspirations to increase the use of sustainable aviation fuels with some suggesting that SAF were not as desirable nor as reliable as was assumed by the discussion document. This included comments that biofuels had a “mixed track record” (e.g. for land vehicles), concerns that the ‘feedstock’ used for the manufacture of SAF may not be genuinely sustainable or renewable, and that there may be negative implications/contradictions of increasing SAF on such things as policies linked to land use, food supply and waste reduction, etc. While the ‘feedstock hierarchy’ gave some confidence, the true sustainability of SAF was still questioned by others.

Environmental NGOs who took part in the workshop welcomed the emphasis on high environmental criteria for SAF and noted the need to learn lessons from the use of biofuels in other areas. Workshop participants also recognised the challenges around feedstock supply and environmental NGOs suggested that demand reduction also needed to be considered, as less SAF would be needed if there were fewer flights. Some aviation industry representatives suggested that power to liquid fuels using carbon capture or ring-fencing a certain amount of feedstock for SAF may provide a solution. The need to align with agricultural policy was also mentioned at the workshop, as this could help with feedstock supply.

A small number of online participants also stressed that SAF were not unproblematic in their use and some instead favoured hydrogen-electric over biofuels as the way forward for what they perceived to be truly sustainable aviation travel. Supporting and investing in hydrogen infrastructure was also encouraged as well as more piloting of drones and unmanned aerial vehicle technology to replace non-passenger flights. Opposite views were offered by a small number who felt that use of SAF would provide an invaluable bridge while alternative technologies and infrastructure were still being developed:

Many low/zero-emissions aviation technologies are, while promising, still in the early stages of development and some distance from commercial deployment, so Sustainable Aviation Fuels can provide a vital early-stages measure towards decarbonising aviation while other technologies mature.”
(Business Representative Body)

Others suggested that use of SAF alone would not be sufficient to deliver the required emission reductions and the Scottish Government was cautioned against over-reliance on SAF in meeting targets.

Workshop participants referenced the work that the UK Government was doing in this area, including considering a ‘Contract for Difference’ like mechanism for SAF as well as the SAF mandate consultation, both of which could be considered in the development of the Aviation Strategy.

A minority disagreed that SAF was ‘sustainable’ and expressed views that genuine sustainability required shifting away from air travel per se.

Q3. What do you think the Scottish Government can do to help ensure a just transition to net-zero for the Scottish aviation sector?

There were disparate responses to this question with a broad range of suggestions for ensuring a just transition to net-zero for the Scottish aviation sector.

Cross-sectoral approach

Support for the travel sector throughout the transition was also stressed by many and, in particular, support for aviation workers. The potential for those employed in the aviation sector to be negatively impacted by the proposed changes was noted with a need for them not to be disadvantaged but supported:

…the Scottish and UK Government should use this opportunity to support further research and development to enable the creation of new green aviation jobs as part of the transition towards net-zero.”
(Business Representative Body)

Environmental NGOs that attended the workshop suggested that a just transition could not be done on a sectoral basis but needed to be across the economy. While there might be fewer jobs in aviation due to the need to reduce demand, the Scottish Government should still seek to ensure that there are other good quality jobs available, and support individuals in acquiring the new skills they needed to transition.

Workforce Training and Skills

Investment in training and skills for those working in aviation and other carbon intensive industries was also suggested by several online respondents, including retraining those already in the industry and supporting workers to remain in employment during any transition to new technology:

This process should be used to inform priorities for government/corporate investment in training and skills for workers who need to transition either to alternative jobs within a transformed aviation sector, or to another sector where their skills will be utilised.”
(Environmental NGOs/representative bodies)

The scope to develop a new skills base and create skilled jobs in green aviation was highlighted and, again, some respondents urged creation and investment in a domestic SAF industry:

By working with existing airport and airline operators to support retraining in these skills, as well as looking for opportunities to retrain high-skilled workers from other sectors such as
nuclear or oil and gas, there is a real opportunity to make this a Just Transition not only for the aviation sector but across a range of regions and sectors.”
(Business Representative Body)

Domestic SAF is also important to ensure that Scotland can have greater control over delivering their own net zero goals rather than relying on the import of SAF from abroad.”
(Aviation and associated industries (including representative bodies)

Workshop participants noted that, while the necessary skills may already exist in Scotland to enable SAF use and production, hydrogen was more challenging. As well as needing the safety regulations in place to support growth in this area, it would be helpful to have guidance to help organisations train their staff for its safe transportation, storage and refuelling, they suggested. Workshop delegates also noted that it is too early to determine the skills workers might need for the use of electric/hybrid aircraft until it becomes clear which kind of aircraft will be used and how they will be recharged.

Partnership working

Engagement of all relevant stakeholders in taking this part of the strategy forward was stressed again, including Scottish and UK governments, local communities, customers, employees and employee representative bodies, suppliers, industry and educational institutions:

We recommend that the Scottish Government use its convening power to bring industry sectors together in pursuit of the required solutions. For example, the transportation, infrastructure and energy sectors must work together to co-ordinate efforts in response to net zero goals.”
(Aviation and associated industries (including representative bodies))

Engagement must be wide ranging and far reaching both within the UK and international context to secure a wider policy environment that secures a just transition, it was suggested.

Communications/messaging

Both aviation industry representatives and environmental NGOs suggested that the messaging around low and zero emission aviation needed to be clearer to ensure a just transition, although these groups expressed different concerns around communication.

Among aviation industry respondents, views were expressed that careful messaging throughout the transition was needed to avoid excessive blame being projected onto the aviation industry for emissions (with accurate and transparent data being available to show the relative contribution of aviation to overall emissions compared to other modes). This was key to minimise risks of the aviation sector being alienated (post-COVID), especially in relation to travel and tourism:

There must be a positive dialogue surrounding travel and tourism during the transition. Travel is not the enemy - carbon is - and the Scottish Government must support messaging around how responsible international tourism is a force for good.”
(Aviation and associated industries (including representative bodies))

Aviation industry representatives at the workshop also stressed that, due to the economic and social benefits achieved from air travel, decarbonisation needs to be done in a way that does not deter/stop people from coming to Scotland. Communication should also be transparent about future regulations required to reduce emissions, it was suggested.

For environmental NGOs and representative bodies, there were also views that public awareness should be increased specifically around the total environmental impact of flying:

The cost of flying to the climate affects the wider population, while the benefits are enjoyed by a relatively small group of people. It would therefore be unjust to allow the aviation sector to continue its climate-destroying practices while carbon reductions are made elsewhere.”
(Environmental NGOs/representative bodies)

Challenging individual travellers’ behaviour to encourage behaviour change (including, for example, promotion of individual carbon calculators) was again suggested by a small number of respondents.

Environmental NGOs also stressed that any public messaging around low and zero aviation needed to be realistic about the limits of technology to solve the problem. At the workshop, it was also suggested that the Scottish Government could strengthen the narrative on ongoing actions and commitments to lowering emissions, and on airspace modernisation and its benefits, to increase public awareness.

Among all groups there was consensus that a just transition would require never excluding or disadvantaging vulnerable or marginalized groups within society as well as protecting lifeline services for rural, remote and island communities.

Avoiding negative economic consequences

It was suggested that financial support (grants or loans) for the shift to new technologies/new fleets and to incentivise operators, as well as to minimise the costs of transition being passed directly to passengers (e.g. through increased ticket prices) would help operators to step into the future. One respondent specifically suggested utilising the £500M Just Transition Fund to provide grants to support Scotland’s SAF and aviation research and development projects to support the Scottish aviation sector’s net-zero transition.

Ensuring that airports are effectively serviced by local (surface) transport networks and improving public transport access also featured in several responses:

…aviation needs to be considered as part of an integrated transport system and net zero for ground access and support services should be achieved as soon as possible at all Scottish airports.”
(Transport Partnership)

Other comments

Many reiterated earlier support for research, development and testing of new technologies, including hydrogen and electric aircraft and offered support for sustainable aviation fuels in response to this question. In particular, support to Scottish academia and industry in the maturing of technology was suggested to avoid a reliance on foreign developed solutions. Separate, specific focus on smooth transitions for rural, island and isolated communities was also encouraged:

…work closely with Scotland’s airports and airlines to support further trials of electric and green aircraft, particularly in the Highlands and Islands where short distance flights offer excellent opportunities for testing.”
(Business Representative Body)

At a more fundamental level, a minority of respondents questioned if a ‘just transition’ was possible or desirable. Some workshop participants considered that there may be different interpretations of what is meant by a ‘just transition’ and what it would entail, and said it would be useful for the Scottish Government to offer further clarification. The process of change must start immediately, some suggested, with minimal scope for delays in the development, testing and implementation of alternatives in order to help avert the climate crisis:

I disagree with the proposal for a ‘just transition’. What is needed is drastic and immediate action. While this would no doubt cause disruption it would also send the strongest message to industry that it needs to change, and fast.”
(Individual)

Finally, it was suggested that thought could be given to how Public Service Obligations (PSOs) could be structured to support a just transition.

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