E-mail to Ed Miliband
Ed Miliband’s comments about aviation which I read in the Guardian in July were sufficiently ridiculous that I wrote him an e-mail detailing my concerns. The correspondence which ensued is documented below.
To: Ed Miliband
Date: 14th July 2009 18:17
Subject: Your comments re: aviation and climate change
Dear Mr Miliband,
I read with concern this morning your remarks which suggested that maintaining current levels of air travel is compatible with attempts to cut our national carbon footprint.
Firstly, this idea is a mathematical near-impossibility. We are legally bound to cut our carbon dioxide emissions by 80% by 2050. Aviation emissions at present levels constitute 10–15% of our national carbon dioxide equivalent output. This would leave the remainder of the economy (99.22% of it, given that aviation constitutes 0.78% of total business turnover) fighting over only 5–10% of emissions. A challenging 80% cut turns into an enormous 90–95% cut which will undoubtedly have major economic and social repercussions. All this assumes that aviation will not grow, contrary to government projections and ambitions on the topic.
Secondly, the egalitarian basis for your position is disingenuous. You say that you ‘don't want to have a situation where only rich people can afford to fly.’ Surely you are aware that this is the situation right now. As detailed in a report by Oxford University’s Environmental Change Institute, ‘available data show that air travel is still primarily undertaken by richer sections of society, and that aviation is not a socially inclusive activity.’ This is probably because other expenses associated with travelling are prohibitive for the poorer members of society, no matter how cheap the flights are. Indeed, the report further suggests that ‘new charges are likely to be socially progressive since the profile of aviation use means that they are primarily likely to deter richer members of society from flying more.’
The report is available here:
http://www.eci.ox.ac.uk/research/energy/downloads/predictanddecide.pdfI feel that your position on this issue flies in the face of the evidence available, and would strongly urge you to reconsider.
Yours sincerely,
Andrew Steele.
Response ¶
After nearly two months, I am frankly appalled at the quality of the below response. In fact, I’d almost recommend you don’t read it, it contains so little information.
My response follows. That is more worth reading, even if I say so myself.
To: Andrew Steele
Date: 2nd September 2009 20:27
Subject: Response to your Query : - Ref:DWOE000147902 - Re: climate change
Dear Mr Steele
On 3 October 2008 the Prime Minister announced the creation of a new Department of Energy and Climate Change (DECC). The new department brings together much of Defra’s previous climate change responsibilities with the energy component from what was at the time the Department for Business Enterprise & Regulatory Reform, to focus on solving the challenges of climate change and energy supply. Defra is currently responding to letters on these issues on behalf of DECC.
Thank you for your recent email about aviation. I have been asked to reply.
We forwarded your previous email on to the Department for Transport (DfT) as it relates to policy in transport. DfT would be best placed to provide the guidance you seek. You may like to follow up with them direct using the details available here:
Regarding the views of the Department and Ed Miliband, however, we think a comprehensive approach to tackling climate change needs to include emissions from international aviation, so we changed the Climate Change Act to require that they are included in our targets and budgets by the end of 2012, or that the Government will have to explain to Parliament why not. This provides time to reach an international agreement on how to allocate these emissions between countries.
We are not in favour of unconstrained growth in aviation. Neither, though, do we think that the cut in emissions needs to be 80 per cent in every single area. We believe that a more pragmatic approach is to cut more in some areas and recognise the extra difficulties in others.
As the independent Committee on Climate Change wrote in their December report, ‘aviation is likely to grow as a percent of all emissions. This is not in itself undesirable: in a carbon-constrained world fossil fuels should be used in those applications where alternatives are least available’—in other words, aviation.
We do not believe it is possible to say we will freeze any growth in flying, given likely passenger demand. Instead, we believe in constrained growth in aviation.
The UK has the most stringent emissions control regime for aviation of any country in the world, based on three components. The first is that we must take account of aviation emission in delivering our targets under the Climate Change Act. We led the fight to include aviation in EU wide emissions trading, which puts a cap on aviation alongside other sectors of the economy. We have gone even further as a country and committed to a new limit; by 2050, UK aviation emissions will be at 2005 levels. Therefore any growth in flights will have to be covered by more efficient engines and aircraft, more efficient air traffic management, and funding the most cost effective reduction measures through emissions trading.
I hope this is helpful.
Yours sincerely
Andrew Glynn
Customer Contact Unit
Defra
My response ¶
To: ccu.correspondence
Date: 2nd September 2009 22:11
Subject: Re: Response to your Query : - Ref:DWOE000147902 - Re: climate change
Dear Andrew,
Thank you for your response.
Given that I have waited nearly two months for a reply, I would have hoped for something which at least addressed the questions in my original e-mail. You have not adequately answered my first query, merely made a few vague statements about probable distribution of emissions reductions between sectors of the economy, and you have failed entirely to engage with my second point, about the socioeconomic profile of air travellers. I will therefore re-state my queries as direct questions.
- Is it Defra policy, and the opinion of Mr Miliband, that it is tenable for aviation, which is responsible for less than 1% of UK GDP, to be responsible for 50–75% of our carbon dioxide emissions by 2050? If not, can you provide any compelling evidence that the turnover/emissions ratio will change in any significant way before 2050?
- Do Defra and Mr Miliband acknowledge that, far from being a socially inclusive activity, aviation is and will continue to be a pastime of the wealthy, as the data in the ECI report demonstrate?
I am very keen to get a personal clarification from Mr Miliband on these points, because his passionate defence of flying in the Guardian suggests following an impossible policy for invalid reasons.
Your e-mail also raises some supplementary questions about Defra’s aviation policy.
- Do Defra and Ed Miliband consider that ‘the Government [having] to explain to Parliament why not’, as you stated in your response, is a sufficient sanction to ensure that international aviation emissions are included in emissions budgets from 2012?
- You state that ‘We do not believe it is possible to say we will freeze any growth in flying, given likely passenger demand.’ Is it Defra’s opinion that environmental policy should be dictated by consumer demand rather than climate science?
I look forward to your prompt response.
Many thanks,
Andrew.
Twinterlude ¶
The conversation continues via Twitter:
@EdMilibandMP I am appalled by the guff your department has sent me in response to my e-mail to you two months ago.
@statto i have read the reply. dont agree it is guff....why do you say that?
@EdMilibandMP Er, because it doesn’t answer either of my questions..? Did you read my response?!
@statto 1. i dont thk your figs r right, not borne out by CCC report either.
2. richer people fly more but so do millions of others. Flying will bec. more xpensive, q is how much+what reductions should we aim for....
@EdMilibandMP I have references for my numbers here. What’s wrong with them? > 140 character response appreciated!
My > 140 character response ¶
Thanks for responding. Here are the references for my figures. Please let me know if you see any problems. Twitter is too short a medium for constructive debate with references, so feel free to leave a comment or get in touch by e-mail. Cheers!
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The Committee on Climate Change page about aviation does not seem to make reference to UK emissions as a fraction of our total CO2 output. I do not understand why not. It claims that aviation represents 2% of global emissions, of which the UK contributes some 8% (we have 1% of World population).
In fact, as well as being global, this figure is out of date (it’s from 1990) and does not take into account the factor of 2.7 extra ‘carbon dioxide equivalent’ radiative forcing created by the chemistry of other aircraft emissions such as water and nitrous oxides, as recommended by the IPCC.
In fact, you can see from the Parliamentary Hansard of 2007 that aviation contributed some 6.3% of UK CO2 emissions in 2005, which rises to 15% when multiplied by 2.7, assuming that the rest of the economy has a radiative forcing index of 1, as the IPPC do. For some unstated reason, the Hansard radiative forcing figure is a factor of 2, leading them to conclude 13%. Indeed, there is some uncertainty in the figure, so I think that aviation contributes 10–15% of current UK emissions is a fair estimate.
If we are to cut our emissions by 80% by 2050, this leaves us with 20% of emissions to play with. 10–15% out of 20% is 50–75%. This assumes aviation emissions do not grow from 2005 levels.
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Aviation is responsible for 0.78% of UK business turnover, according to the Office for National Statistics.
What is wrong with my figures?
‘Richer people fly more but so do millions of others’ is disingenuous. Expanding aviation overwhelmingly benefits the wealthy. The ECI report states that ‘the indication is that the majority of the growth in aviation has occurred because richer people are flying more often.’ Growing aviation is therefore not the socially inclusive course of action you claim when you say that you ‘don't want to have a situation where only rich people can afford to fly.’
Finally, do you have answers to my subsequent two questions regarding the e-mail response I received yesterday?
More via Twitter ¶
@statto u r hrd to please! will get u more than 140wd reply. NB: we want aviation and shipping deal in c'hagen
@EdMilibandMP Certainly am. :) Thanks, looking forward to it.
Where it comes to millions of lives in the developing world and the state of the entire UK economy…I suppose I am a bit tricky to please, yes.
Another response—October ¶
I received a response from DECC in October whilst on holiday, and have only just had chance to get back to them. Their response appears to be mainly cherry-picking and obfuscation and, whilst it does engage with my queries to a slightly greater degree than previous correspondence, they still have not addressed my direct questions, which I was forced to restate again at the end of my reply. Both e-mails are copied below.
To: Andrew Steele
Date: 12th October 2009 12:36
Subject: Response to your Query : - Ref:DWOE000152630 - FW: Aviation and climate change
Dear Mr Steele
Thank you for your follow up email to Ed Miliband of 20 September about aviation emissions. I have been asked to reply on behalf of the Secretary of State and apologise for the delay in doing so.
You have raised a number of important points, and I will attempt to address them in turn. We also acknowledge the publishing of our correspondence on your blogsite, and would indeed like to encourage debate in this area.
It is perhaps misleading to assert that flying is purely a pastime of the wealthy. The Office of National Statistics Omnibus Survey in 2008 showed that with “Public experiences of and attitudes to air travel” (compared to 1991) in 2008 2.9 million more passengers (UK residents) from the poorest social groups benefited from flights from the 5 major London airports. This represents an increase of 149% increasing as a proportion from 5.6% to 6.4% of all passengers.
On your question regarding aviations share of carbon dioxide emissions, the Committee on Climate Change have estimated that if gross aviation emissions were limited to 2005 levels in 2050 in developed countries, as the UK has committed to do, this would result in aviation emissions accounting for 25% of total allowed carbon dioxide emissions in 2050 based on developed countries adopting the UK’s domestic target of 80%. Our method is to target policies and measures on where our analysis is clear that the most cost effective reductions can be made, and not arbitrarily selecting any one sector.
We also recognise that aviation’s climate change impacts extend beyond that of its carbon dioxide emissions alone. However, currently there is no suitable climate metric to express the relationship between emissions and climate warming effects from aviation although it is an active area of research. Nonetheless, it is clear that aviation imposes other effects on the climate which are greater than that implied from simply considering its CO2 emissions alone.
The application of a ‘multiplier’ to take account of non-CO2 effects is a possible way of illustratively taking account of the full climate impact of aviation. A multiplier is not a straight forward instrument. In particular it implies that other emissions and effects are directly linked to production of CO2, which is not the case. Nor does it reflect accurately the different relative contribution of emissions to climate change over time, or reflect the potential trade-offs between the warming and cooling effects of different emissions. Therefore, we generally exercise caution in applying a multiplier that attempts to capture all of the radiative forcing effects of aviation’s emissions.
However, this does not mean we are not pursuing further measures to address aviation’s non carbon dioxide impacts alongside action on its carbon dioxide emissions, such as supporting the development of a regulation for NOx emissions – a proposal the Commission is currently developing and supporting EU research into re-routing flight paths to avoid areas where contrails and cirrus clouds are likely to form.
It is not insignificant, that there is a legal requirement for the Secretary of State to inform Parliament of a decision on the timing and method for inclusion or not of international aviation emissions in the UK’s carbon budgets. Government will make a judgement on the matter of inclusion based on the Committee on Climate Change’s advice. The price of not meeting our emission targets may be imposed onto us by the European Council, but it would be inappropriate to second guess what this could be.
However, I am sure you will agree that any financial burden would not compare to what we may face in the form of dangerous climate change. Copenhagen, as has been said before, is our make or break deal. Whilst the UK has led the way in terms of legislation and ambition, we still have to clinch ‘the deal’ with every nation, in a fair and transparent way; to agree on environmentally, economically and socially sustainable solutions and a viable path of transition before it’s too late.
If you or your readers would like to keep abreast of events and news in the run up to Copenhagen, please visit www.actoncopenhagen.gov.uk
Yours sincerely,
Jonathan M Jones
Customer Contact Unit
Defra
My reply—December ¶
To: CCU correspondence, CC: Ed Miliband
Date: 6th December 2009 22:39
Subject: Re: Response to your Query : - Ref:DWOE000152630 - FW: Aviation and climate change
Dear Jonathan,
Many thanks for your response and my apologies for the delay in replying.
Firstly, regarding the socioeconomic profile of air travellers, I would agree with you that it ‘is misleading to assert that flying is purely a pastime of the wealthy’. I didn’t use the adverb ‘purely’; were I to have used an adverb, I might have chosen ‘largely’.
I searched the Web for the omnibus you describe, but in spite of finding several documents spread over the ONS and DfT websites I could not find a source for the statistic you cite. Would it be possible for you to provide the details of the collection and analysis of the data which led to this result?
However, I think that we are quibbling over what looks like a cherry-picked statistic; the DfT’s summary of the ONS omnibus, which can be found here states:
‘Those in the highest income group (earning £31,200 or more per year) were particularly likely to have flown three or more times in the last year (48%). People in this group were far more likely to make all three types of flight (domestic, short-haul and long-haul) than those in lower income groups. For example, among the highest income group, 24% had made domestic flights, 68% short-haul flights and 43% long-haul flights. The respective figures for those in the lowest income group (less than £5,200 per year) were far lower at 1%, 24% and 17%.’
These conclusions unequivocally contradict your point, ostensibly from the same survey data.
Concentrating on UK statistics also neglects the huge global inequities with regards to access to aviation—as I stated previously, we are responsible for 8% of emissions whilst only possessing 1% of the World’s population. Flying is most certainly largely a pastime of the rich on a global scale.
I am aware of the Committee on Climate Change estimates for carbon dioxide emissions from aviation, and have outlined my objections to them both to your department and the CCC themselves, from whom I am awaiting a response. However, even if we assume their estimates are correct, does Mr Miliband and your department consider it viable for a sector contributing 1% of UK GDP to be responsible for a quarter of our carbon dioxide emissions?
I am also slightly confused by your policy on radiative forcing multipliers, since you seem to be suggesting that an imperfect measure is worse than no measure at all! You admit that ‘it is clear that aviation imposes other effects on the climate which are greater than that implied from simply considering its CO2 emissions alone’, but suggest that including this in calculations, which can of course be done with an associated numerical error to take into account the uncertainties, would somehow make estimates of aviation emissions worse. I cannot understand this logic.
Obviously I applaud research into minimising the positive radiative forcing of contrails and other non-CO2 emissions, but I fail to understand how you can assess the worth of these measures if you refuse to quantify their effect!
You say that ‘It is not insignificant, that there is a legal requirement for the Secretary of State to inform Parliament of a decision on the timing and method for inclusion or not of international aviation emissions in the UK’s carbon budgets.’ However, I am not convinced that you make an argument for this position, but simply state who is accountable to whom. Having stated that any fine will be far outweighed by the financial repercussions of failing to address climate change, I cannot understand what purpose the fine serves—and I certainly can’t see how it would act as an incentive for a government minister.
The global agreement in Copenhagen and British climate policy must be based on the best available science and economics, and therefore I would appreciate direct answers to my questions, restated below:
- Is it Defra policy, and the opinion of Mr Miliband, that it is tenable for aviation, which is responsible for less than 1% of UK GDP, to be responsible for 50–75% [or even 25%, if you still wish to ignore non-CO2 emissions] of our carbon dioxide emissions by 2050? If not, can you provide any compelling evidence that the turnover/emissions ratio will change in any significant way before 2050?
- Do Defra and Mr Miliband acknowledge that, far from being a socially inclusive activity, aviation is and will continue to be [largely] a pastime of the wealthy, as the data in the ECI report, the ONS omnibus and global emissions figures demonstrate?
- You state that ‘We do not believe it is possible to say we will freeze any growth in flying, given likely passenger demand.’ Is it Defra’s opinion that environmental policy should be dictated by consumer demand rather than climate science?
Many thanks,
Andrew Steele
The brush-off ¶
I have to admit I’m dumbfounded by this comeback from DECC. Basically, they are refusing point-blank to engage any further on this issue, in spite of having failed repeatedly to address my questions, re-stated in each e-mail I sent. Their only attempt to address one of my queries was with statistics which they have failed to provide a source for.
Careful thought about the future of aviation is crucial to fighting climate change without crippling our economy. The fact that Ed Miliband and his department refuse to answer my questions on the subject is not just insulting, and doesn’t just make a mockery of representation and raise questions about the point of their ‘customer contact unit’, but exposes a deeply worrying gap in UK government policy.
To: Andrew Steele
Date: 4th February 2010 15:49
Subject: Response to your Query : - Ref:DWOE000162390 - Re: Response to your Query : - Ref:DWOE000152630 - FW: Aviation and climate change
Dear Mr Steele
Thank you for your further follow-up email of 6 December to DECC. I apologise for the delay in replying.
Future correspondence from you will be acknowledged but we will not issue a full response unless new issues are being raised. I am sorry to have to give you this disappointing news, but please understand that the Department has a duty to ensure that its resources are being used in an effective and productive manner.
As a Department, we try hard to provide clear and helpful information in response to requests from DECC customers. In the last year or so, we have received a number of e-mails from you about energy and climate change issues, and we have endeavoured to provide you with relevant information on the Department's policies and activities. I am sorry if our responses have not been helpful to you.
Having reviewed the recent exchanges and consulted carefully with senior colleagues and policy experts from around the Department, I have concluded that there is nothing that we can usefully add to our previous responses that would address these matters to your full satisfaction. In the circumstances, there seems little to be gained by continuing this correspondence.
Yours sincerely,
Laura Smith
DECC Customer Contact Unit
Patel says (20:58 05/02/2010) ¶
This looks very much like a form letter doesn't it? Not such a bad thing I suppose - I guess the civil service have to have some procedure in place the kick what they see as crank correspondents into the long grass, but they do seem to have applied this policy with unseemly haste in your case don't you think? I wonder how many other correspondents are filed under 'too difficult' and get summarily despatched in this way?