Call for evidence outcome

2040 zero emissions airport target

Updated 3 May 2023

Applies to England

Ministerial foreword

Aviation will become one of the world’s largest emitting sectors by 2050. Millions of flights take off and touch down around our planet every single year, and all parts of the industry must act to fix our changing climate.

As an industry, aviation is inherently global in nature, and this makes it one of the most challenging modes of transport to decarbonise. But the UK is intent on rising to that challenge, and our Jet Zero Strategy set out our vision for an aviation sector which reaches net zero emissions by 2050.

This is a stretching goal, and whilst we are ambitious, we are not naïve. We recognise that some parts of industry will need more time, and that in other areas workable solutions already exist and can be accelerated.

That is why we have set a more ambitious goal for all airport operations in England to be zero emission by 2040. Airport operations are fertile ground for nurturing existing solutions and boosting the industry’s commitment to net zero by 2050.

These zero emissions airports will be emblematic of aviation’s long-term future. We want millions of passengers who use airports to experience clean and green places. Places that remind us all of the benefits of securing a sustainable aviation future.

That future will be shaped by the whole industry, and we need the whole industry to share their views. We need to better understand the way we define airport operations, emissions sources and entities in our zero emissions goal. We rely on your expertise to understand how we best implement the target, and measure and monitor emissions to ensure it is achieved. This is your opportunity to give your perspective on how we may look to achieve our target while continuing to reap the benefits of the aviation industry.

Baroness Vere of Norbiton, Minister for Aviation

Why zero emissions airports?

In 2019, the UK became the first major economy to legislate to end its contribution to climate change by 2050. This requires us to reduce emissions across all sectors of the economy, including hard to abate sectors such as aviation. However, the transition to net zero also provides significant opportunities to create new green jobs, improve our energy security and resilience, and drive long-term growth by attracting early investment in new transport technologies.

Ambitious targets are needed economy-wide to meet our net zero goals. Transport is currently the largest emitting sector of the UK, responsible for 24% of the UK’s total emissions in 2020. Decarbonising aviation is a huge challenge across the global economy and, in two out of three scenarios in the Net Zero Strategy (NZS), is set to become one of the largest residual emitters by 2050.

Therefore, in July 2022 we published our Jet Zero Strategy (JZS) which set out the government’s approach to achieving net zero 2050 for UK aviation, informed by over 1,500 responses to the Jet Zero Consultation and the Jet Zero: further technical consultation. The strategy focuses on the rapid development of technologies in a way that maintains the benefits of air travel, whilst maximising the opportunities that decarbonisation brings to the UK. It also sets out a CO2 emissions reduction trajectory that sees UK aviation emissions peak in 2019. The strategy was followed by a global commitment at the 41st International Civil Aviation Organisation (ICAO) Assembly to net zero emissions from international aviation by 2050.

We recognise that aviation is a hard-to-abate sector and that there are parts of the aviation industry which will not be able to decarbonise fully, with 19.3MtCO2e of residual emissions in 2050 expected in the trajectory set for the JZS. Therefore, we must accelerate areas of aviation where solutions already exist, or will exist in the short-to-medium-term, to decarbonise sooner. Airport operations are one of the few areas where this is possible and therefore provide one of the best opportunities for the industry to demonstrate their commitment to Jet Zero with existing zero emissions solutions.

The Airports Council International (ACI) also recognise this issue and have set a long-term aspirational goal for their 1,950 member airports to be net zero by 2050. As this is a global goal, they recognise that some airports will move beyond this goal as they have different levels of maturity. This may include achieving this goal before 2050, addressing more sources of emissions, and advancing to zero or carbon negative emissions.

However, with over two-thirds of airports in England being listed in the Airport Operators Association Decarbonisation Report as having net zero targets before 2040, a zero emissions target for 2040 represents an ambitious next step, which will support the UK’s Jet Zero goals, as well as ambitions at a global scale.

In addition, there is an important co-benefit to decarbonising airport operations, which is an improvement in air quality. Transitioning to non-fossil fuel powered airport operations, such as using electric vehicles and zero emission heating and energy systems will likely result in a significant decrease in both nitrogen dioxide (NO2) and particulate matter (PM10) concentrations around airports. This could reduce the occurrence and severity of respiratory illnesses for those living in the vicinity of airports, as well as airport users and employees.

Prior to the COVID-19 pandemic, the air transport and aerospace sectors combined contributed £22 billion to annual GDP. Air transport directly employed nearly 150,000 people and supported up to half a million more jobs across the UK, in aviation and aerospace.

Airports serve as an effective place for business, forming natural hubs, which provide accessibility, security, convenience and can provide a wealth of talent and skills. Heathrow alone is predicted to contribute approximately £4.7 billion to the UK economy by 2025 and is set to support more than 140,000 jobs. But it is not just large airports that have an impact. Smaller regional airports provide key air services, such as connecting remote areas, flight training, specialist and business aviation, and special mission aviation (such as Search and Rescue, the National Police Air Service and air ambulances), as well as supporting levelling-up ambitions. The zero-emissions airport target is not intended to hamper economic growth at airports, but to provide a social licence for growth.

We recognise that there are a range of airports in England that compete with one another, and with other UK, European and worldwide airports for passenger and freight traffic. As we develop this policy, we will carefully consider how best to maintain fair competition between airports.

Progress to date

In our Jet Zero consultation published in July 2021, we proposed a target for all airport operations (Scopes 1 and 2 as described in ‘the target’ section) in England to be zero emissions by 2040. We received over 1,400 responses to the consultation, with mixed feedback on the airport target. These comments were largely around why airports are being treated differently to other similar infrastructure such as shopping centres and rail freight terminals.

Some airports suggested a net zero airport operations target may be more appropriate for 2040, rather than zero emissions, highlighting various infrastructure challenges for industry including the replacement of gas-powered heating. Organisations such as NGOs, environmental groups and consultancies considered the target could be more ambitious and could include Scope 3 emissions (as described in ‘the target’ section).

To support our understanding of the achievability of this target, DfT commissioned Mott MacDonald, through the Connected Places Catapult, to undertake a technical feasibility study. Although our proposal was for airport operations in Scope 1 and 2 to be included in the target, this study expanded to Scope 3 emission sources to ensure sufficient understanding of the whole airside operating system.

The outcome of the study was that it is feasible from a technology and commercial perspective for airports to achieve zero carbon emissions from Scope 1, 2 and 3 airport operations by 2040.

The report highlighted that most of the technology is either available now at a commercial level, or at least prototype level. For those technologies where there is currently no zero-carbon solution e.g. fire tenders and some ground handling equipment, the report found that these solutions should be available by 2040.

The study also began to explore some of the issues surrounding the commercial feasibility of deploying these technologies stating “some of this technology will exist at a price point beyond that which is affordable, and the time requirement to implement technology change may also prevent zero carbon airport operations by 2040. If the right commercial model and incentives can be put in place in time, then it is feasible to reach zero carbon by 2040”. We explore this more in the implementation section of this call for evidence.

We have also conducted further stakeholder engagement with airports and other interested stakeholders to further understand the issues surrounding the scope and implementation of the target.

In our Jet Zero Strategy published in July 2022, we reconfirmed our ambitions for airport operations in England to be zero emissions by 2040, recognising that while there is still more work to be done on ensuring this target can be implemented in a fair and achievable way, it is the right level of ambition. As stated in our government response to the Jet Zero Consultation, we have noted the concerns of some airports, but given the difficulty of decarbonising the sector overall, we want those parts that can decarbonise more quickly, to do so.

While this target considers airports in England, the government will work closely with the devolved administrations on the decarbonisation of airports to ensure the maintenance of a competitive airports sector throughout the UK.

Current Industry Initiatives

The Airport Carbon Accreditation (ACA) scheme was established by the 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.

ACI Airport Carbon Accreditation Levels

• 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.

The scheme is a voluntary scheme and is open to airports of all sizes, extending beyond hubs and regional airports with scheduled passenger traffic, to include general aviation and freight focused airports. 12 airports in England are currently part of this scheme, with 9 of these achieving Level 3+ or above.

This scheme has proven an effective tool to support airports in reducing their impact on the climate. We recognise a strong desire within industry for the policy underpinning our target to align with this scheme to avoid unnecessary burden on airport operators and we will work closely with the ACI going forward as we develop our policy. However, we need to consider the fact that the scheme does not have a time-bound emissions target, and not all airports participate in this scheme.

The need for a call for evidence

Our ambition is for airport operations in England to be zero emission by 2040, but to put this target in place we need to gather more information to help design the policy, including the scope of the target and route for implementation.

Therefore, in helping to develop the scope and implementation of the target, we intend to use this call for evidence to:

• get feedback on the definition of airport operations
• get feedback on the emissions sources that should be included within the target
• gather information to help determine what entities the target should be applied to
• gather information to help determine the type and size of airport the target should be applied to
• understand how the proposed target could be aligned with current schemes, such as the ACI ACA
• gain initial feedback on the potential regulatory or voluntary approaches that could be used to implement the target
• collect information on the barriers and opportunities which may exist in implementing the target, including commercial feasibility
• gather evidence on what the appropriate measuring and reporting processes should be

The target

Airport operations can include any activity that serves an airport, undertaken by a range of entities, both within the airport’s site boundary and off-site. In setting this target, we must look to clearly define what is and is not in scope, considering the emission sources, and responsible entities.

Defining airport operations

Each airport is unique and will have a different understanding of what airport operations are.

For the purposes of this target, 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
• the manoeuvring, parking, refuelling, or servicing of aircraft between landing and take-off at the airport
• the transport and processing of persons, baggage, and cargo between their arrival at the airport and their departure, including the passenger terminal

We believe that airport operations should include infrastructure that supports surface access (e.g., car parks, car rental infrastructure, bus stations, tram stations and railway stations). However, we recognise that the ownership and location of surface access infrastructure varies between airports and would welcome views on how best to include this infrastructure within the target.

We believe that the airport operations should exclude on-site hotels, unless they are situated in a passenger terminal that forms part of the airport.

Question 1: Do you agree or disagree with the proposed definition of airport operations for the target? Explain your response.

Question 2: If you disagree with the proposed definition of airport operations, what do you think, if anything, should be added to the definition?

Question 3: If you disagree with the proposed definition of airport operations, what do you think, if anything, should be removed from the definition?

Question 4: What, if any, further views do you have on the proposed definition of airport operations for the target?

Emissions scopes

The following sections will consider emissions sources pertaining to Scope 1, 2 and 3 emissions. Under the Greenhouse Gas (GHG) Protocol (the global standard for companies and organizations to measure and manage their GHG emissions), these scopes are defined as follows.

Emissions scopes

Scope 1

Direct 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 e.g., for an airport operator this includes aircraft movements, and surface access for airport users i.e. 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), and sulphur hexafluoride (SF6).

Question 5: Do you agree or disagree on the target being applied for the Kyoto gases as described in the GHG Protocol? Please provide detail if you disagree.

Emissions sources in scope of the target

We must also consider which emissions sources occur within the definition of airport operations, and whether they should be in scope of this target.

In the Jet Zero Strategy, we recommended that the proposed target should be applied to Scopes 1 and 2 emissions from airport operations. We recognise that each airport is different and may have different Scope 1 and 2 emissions sources based on their specific activities and facilities. However, we believe the following list 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:

• stationary sources: boilers, furnaces, burners, turbines, heaters, incinerators, engines, firefighting exercises, flares, generators, etc
• mobile sources: vehicles owned by the airport (airside / landside) - trucks, employee buses, ground power units, construction vehicles and plant, etc
• process emissions: onsite waste management, wastewater management
• other: refrigerant losses, de-icing substances, leaks from plant particularly fire suppression CO2, fuel tanks, etc
• energy indirect emissions: emissions from purchased electricity, heating, cooling, etc

Responses to the Jet Zero Consultation indicate that some of the above emissions sources may be difficult to decarbonise by 2040. This may be due to a variety of reasons including technology readiness, commercial viability and/or other factors such as operational issues to ensure a safe service provision. Examples given included fire training, backup generation, and heating/cooling systems.

We are keen to understand the areas that cannot be fully decarbonised, whether this will have a material impact on emissions, and whether there are opportunities to overcome these barriers by 2040.

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 (NRMM) that is used for construction purposes in relation to any building owned or operated by the airport operator to be within scope. This excludes any emissions associated with the access of on-road vehicles to the airport site.

Question 6: Do you agree or disagree with the list of Scope 1 and 2 emissions sources for airport operations? Explain your response.

Question 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?

Question 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?

Question 9: What, if any, further views do you have on the list of Scope 1 and 2 emissions sources for airport operations?

Question 10: What are your views on our current approach to construction and construction vehicles under this target?

Several respondents to the Jet Zero Consultation stated that Scope 3 emissions should also be included in the scope of the target. Specific emissions sources which were raised were aircraft operations at the airport and ground handling conducted by another company.

We believe the following list of 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:

• aircraft: 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, etc
• stationary sources: third party boilers, furnaces, burners, turbines, heaters, incinerators, engines, etc
• mobile sources: ground support equipment (GSE) and ground power units operated by third parties, staff travel/commute, haulage, business travel (third parties), land or maritime surface access (passengers), third party owned vehicles, etc
• process emissions: offsite management/disposal of airport waste, management of waste where disposal arrangements are made by third parties, etc
• infrastructure: grid power and fuel consumed by close partners and other third parties, etc
• other: (where they are not solely controlled by the airport operator) refrigerant losses, de-icing substances, leaks from plant particularly fire suppression CO2, fuel tanks, etc

While an airport operator may have a strong influence over some Scope 3 emissions, they do not have direct control. However, there has been an increasing move for companies to act on their Scope 3 emissions, and at least to measure and report them where possible. Acting on Scope 3 usually takes the form of working in partnership with the entities responsible for these emissions or using influence over contracts with third party organisations.

For example, as part of the requirement for Level 4/4+ of the ACI ACA scheme, airport operators must also 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 >10% of total Scope 1,2,3 emissions (exc. LTO and cruise phase emissions) and over which the airport exercises significant influence.

Question 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) Explain your response.

Question 12: If you disagree with the list of Scope 3 emissions sources for airport operations, what, if anything, should be added to the list?

Question 13: If you disagree with the list of Scope 3 emissions sources for airport operations, what, if anything, should be removed from the list?

Question 14: What, if any, further views do you have on the list of Scope 3 emissions sources for airport operations?

Question 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+? Explain your response.

Question 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? Explain your response.

Exemptions from the target

In considering what emissions sources are in 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 - the first is 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.

Another option would be to set 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. Alternatively, individual activities could be listed as exempt based on a case-by-case assessment.

Question 17: How should any potential exemptions from the target be dealt with? Explain your response.

Entities subject to the target

We understand that there are a range of entities which have direct and indirect control over the emissions that occur as a result of airport operations. There are several emissions sources within our definition of airport operations which are the responsibility of other entities, such as ground handling and air traffic control tower services.

The airport operator has a varying degree of control over these entities. For example, while they may have control over who provides services such as air traffic control at the tower, for other operations like ground handling, the entity is ordinarily chosen by the airline rather than the airport operator.

By applying the target solely to airport operators, this may risk missing a significant source of emissions that are within Scope 1 and 2 of another entity. Therefore, it may be appropriate to apply the target to these entities as well to ensure that all areas able to decarbonise by 2040, do so.

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.

Question 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? Explain your response.

Question 19: Do you agree or disagree that the operational control approach should be used to apportion responsibility for airport operation emissions under the target? Explain your response and if you disagree, which alternative approach would you prefer?

Airports subject to the target

Airports are complex operations where many activities take place. It is also the case that not all airports are alike, and operations can vary considerably depending on size and type of operation. This point was made by several respondents to our Jet Zero Consultation, particularly regarding the size of airports.

By size of airport, we refer below to the number of passengers per annum (measured in millions of passengers per annum or 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.

The difference in passenger numbers between the top 23 busiest airports in England ranges from around 80 million for London Heathrow to just over 64,000 at Land’s End. In their feasibility report on reaching zero carbon airport operations, Mott MacDonald undertook an initial analysis of the impact of airport size on ability to reach the target.

It was found that large airports (above 25mppa) have the greatest feasibility to decarbonise, driven by greater market power. However, medium sized (5-15mppa) 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.

Question 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? Explain your response.

Question 21: Which metric should be used to determine an airport’s size? Explain your response.

Question 22: Which types of airport business operations should the target apply to? Explain your response.

Implementation

How to ensure the target is implemented

There are several policy implementation options to allow us to reach the zero emissions airport operations target by 2040. A key aim will be to guarantee that any approach ensures that the optimum outcome is achieved in terms of emissions reductions under the target, while ensuring unnecessary burden on airport operators and other stakeholders is avoided.

Several options are available for implementation of the target. A regulatory or voluntary approach could be employed, either individually, or in combination to achieve the target. This voluntary approach might allow for this target to be more widely adopted by airport operators and other appropriate stakeholders without the potential need for multiple regulations to cover different sizes and types of operation. However, sufficient controls would need to be in place to ensure that the industry is on track to meet the target and airports are holding themselves to account. It also should be considered whether a penalty for non-compliance is required, and what this may be.

We believe the implementation methods for this target could include:

• a legislative requirement placed on specific entities to reach zero emissions by 2040
• a voluntary agreement, such as an accreditation scheme, where an airport’s adherence to an agreed set of criteria would be regularly assessed and visible to consumers
• a commitment by each airport to produce a roadmap to achieve zero emissions by 2040

Our presumption is that industry should bring forward ideas for implementing a target using their sectoral expertise. There is however a need to ensure fair competition between airports remains and that a target is implemented in a consistent and credible fashion with progress visible to consumers.

Question 23:What policy option do you think is most appropriate for the implementation of the target? Explain your response.

Question 24: What are your views on a voluntary approach to implement the target?

Question 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?

Question 26:Do you agree, or disagree, that there should be a penalty for non-compliance with the target? Explain your response.

Question 27: If there is a penalty for non-compliance, what should this look like?

Question 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
• the availability of finance, especially post COVID-19 where revenues may not be available to cover changes needed
• the impact of regulatory or passenger charges models for airports and the capacity in these systems to allow for change management

However, each airport faces its own challenges and will approach this transition differently. There will be differences in approach between large, medium, and small airports as the different business models will have different drivers and financial pressures. In addition, some airports may have already invested significant amounts of capital in decarbonising their operations, whereas some may be at the beginning of this transition.

In addition to commercial viability there may also be other barriers, such as interdependence on green electricity supply and interactions with other areas of regulation, such as ground handling.

The transition to zero emissions operations will require a concerted effort by all stakeholders, including the government, the CAA, airports, airlines and ground handlers. The Mott MacDonald feasibility study indicated that some government initiatives that could help to achieve zero emissions operations could be to standardise emissions reporting and provide incentivisation for early adoption.

Question 29: What do you think are the main barriers in implementing the target? Explain your response.

Question 30: Do you have an approximation of the scale of investment required to achieve this target? If so, provide any details you have including references to data sources.

Question 31: What financial government initiatives would help to achieve this target?

Question 32: What non-financial government initiatives would help to achieve this target?

Opportunities for implementation

Decarbonisation may bring commercial opportunities for airports. A shift has been seen in recent years of investors transitioning their portfolios to providers that can demonstrate environmental sustainability. This may help airports to not only fund their green investments but their operations across the whole airport system. Decarbonisation may also lead to reduced operating costs in the long term, increase energy security and may help reduce the risk around relying on offsetting and removals, with carbon credits expected to be in high demand in the coming decades.

In addition, 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.

Question 33: What, if any, opportunities do you think exist that could be exploited in the implementation of the target?

Question 34: What technologies are important to achieve this target?

Question 35: Are current government policies sufficient to encourage transition to these technologies? Explain your response.

Question 36:How could the implementation of this target help to support the future shift of airports to integrate hydrogen?

Question 37:How, in your view, should airports look to develop export potential in regard to their transition to zero emission operations? Explain your response.

Measuring and reporting of emissions

The reporting of greenhouse gas emissions is an important part of the process of emissions reduction. It allows identification of ‘hotspots’ of emissions that need to be prioritised, and even in the case of Scope 3 emissions, it can help identify areas where collaboration with stakeholders can have large impacts on emissions reductions. It will also be an essential part of tracking progress of airports towards the zero emissions target to 2040.

The importance of transparency in emissions reporting has been recognised in recent years through the increase in mandatory requirements put on companies to report emissions alongside their annual financial reports.

UK companies are currently required to report their emissions as part of the Streamlined Energy and Carbon Reporting (SECR) requirements set by the UK government.

This requires the annual directors report to state their global greenhouse gas emissions, an intensity ratio (e.g., for aviation, this could be emissions per air traffic movement) and total global energy usage covering Scopes 1 and 2. Scope 3 reporting is only required on a voluntary basis, although it is strongly encouraged, especially where this is a material source (as is the case with airports and large Scope 3 emissions from aircraft movements).

For airport operations that are part of the ACI ACA scheme there are minimum requirements for reporting of emissions based on the level of accreditation. The highest level of accreditation, Level 4+, which aligns most with our 2040 target ambition, requires full reporting of Scope 1, 2, and 3 emissions.

It has been reported that there is a large discrepancy among the ten biggest UK airports in the quality of reported data. Given this difference it must be considered whether reporting requirements will be needed as part of the underpinning arrangements for the 2040 target, in addition to what is already required for companies under SECR. This is not only to allow a full account to be taken of the scale of emissions reductions needed, but also to allow for effective monitoring of emissions year-on-year and to enable fair comparison between different airports.

In considering reporting requirements, we must consider the frequency of this reporting, as well as how this could align with other reporting requirements. Currently, progress against the Jet Zero emissions trajectory will be monitored annually, and the overall strategy will be reviewed every five years, with the first review due in 2027. For airports participating in the ACI ACA scheme, the reporting period is every six years.

We will also need to consider what will need to be measured to monitor progress. This may require an emissions trajectory to be developed to 2040 across all entities or individual entities covered by the target. In early years, carbon reductions may be able to be demonstrated with a reduction in demand for CO2 emitting assets, but it is likely in later years there would need to be increased demonstration that assets were being moved to completely zero carbon sources.

Question 38: What ideas, if any, do you have for how a progress reporting requirement could operate?

Question 39: How frequently should progress towards the target be reported?

Question 40: What are the metrics that you think progress should be measured against?

Question 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? Explain your response.

Question 42: What are, if any, the specific issues you anticipate with regards to increased emissions reporting?

Call for evidence questions

This list of questions is provided to give you an overview of what we are asking. See the Ways to respond section of the call for evidence web page to answer the questions.

1. Do you agree or disagree with the proposed definition of airport operations for the target?

2. If you disagree with the proposed definition of airport operations, what do you think, if anything, should be added to the definition?

3. If you disagree with the proposed definition of airport operations, what do you think, if anything, should be removed from the definition?

4. What, if any, further views do you have on the proposed definition of airport operations for the target?

5. Do you agree or disagree on the target being applied for the Kyoto gases as described in the GHG Protocol?

6. Do you agree or disagree with the list of Scope 1 and 2 emissions sources for airport operations?

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?

9. What, if any, further views do you have on the list of Scope 1 and 2 emissions sources for airport operations?

10. What are your views on our current approach to construction and construction vehicles under this target?

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)?

12. If you disagree with the list of Scope 3 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?

14. What, if any, further views do you have on the list of Scope 3 emissions sources for airport operations?

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+?

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?

17. How should any potential exemptions from the target be dealt with?

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? Please explain your response.

19. Do you agree or disagree that the operational control approach should be used to apportion responsibility for airport operation emissions under the target?

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?

21. Which metric should be used to determine an airport’s size?

22. Which types of airport business operations should the target apply to?

23. What policy option do you think is most appropriate for the implementation of the target?

24. What are your views on a voluntary approach to implement the target?

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?.

27. If there is a penalty for non-compliance, what should this look like?

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?

29. What do you think are the main barriers in implementing the target?

30. Do you have an approximation of the scale of investment required to achieve this target?

31. What financial government initiatives would help to achieve this target?

32. What non-financial government initiatives would help to achieve this target?

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?

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?

38. What ideas, if any, do you have for how a progress reporting requirement could operate?

39. How frequently should progress towards the target be reported?

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?

42. What are, if any, the specific issues you anticipate with regards to increased emissions reporting?

How to respond

See the Ways to respond section on the GOV.UK homepage for this call for evidence to find out how you can respond to this consultation.

The call for evidence period began on 7 February 2023 and will run until 11:45pm, 5 May. Please ensure that your response reaches us before the closing date.

When responding, please state whether you are responding as an individual or representing the views of an organisation. If responding on behalf of a larger organisation, please make it clear who the organisation represents and, where applicable, how the views of members were assembled.

What will happen next

A summary of responses and government response will be published on the gov.uk website. We plan to publish a consultation on this policy following analysis of the responses provided in this call for evidence.

If you have any questions about this Call for Evidence, please contact ZEAirports@dft.gov.uk

Freedom of information and confidentiality

Information provided in response to this call for evidence, including personal information, may be subject to publication or disclosure in accordance with the Freedom of Information Act 2000 (FOIA) or the Environmental Information Regulations 2004.

If you want information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory Code of Practice with which public authorities must comply and which deals, amongst other things, with obligations of confidence.

In view of this, it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information, we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the Department for Transport (DfT).

DfT will process your personal data in accordance with the Data Protection Act (DPA) and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties.

Data protection

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. This call for evidence and the processing of personal data that it entails is necessary for the exercise of our functions as a government department. If your answers contain any information that allows you to be identified, DfT will, under data protection law, be the Controller for this information.

As part of this call for evidence, we are asking for responses via email, which may include your name and will provide us with your email address. We will use this information only for the purposes of asking follow-up questions or notifying you if there is information relating to the call for evidence which it may be useful for you to be aware of.

DfT’s privacy policy has more information about your rights in relation to your personal data, how to complain and how to contact the Data Protection Officer. You can view it at www.gov.uk/government/organisations/ department-for-transport/about/personal-information-charter.

To receive this information by telephone or post, contact us on 0300 330 3000 or write to Data Protection Officer, Department for Transport, Great Minster House, 33 Horseferry Road, London, SW1P 4DR

Your information will be kept securely on the IT system within DfT and destroyed within 12 months after the call for evidence has been completed.

Public Sector Equality Duty (PSED)

The Public Sector Equality Duty (PSED) (s. 149 of the Equality Act 2010) requires public authorities, in carrying out their functions, to have due regard to the need to achieve the objectives set out under s149 of the Equality Act 2010.

The Department for Transport has undertaken an equality analysis in relation to the Jet Zero Strategy and equality impacts will be further explored as individual policies are developed.

We invite comment on how the target for airport operations in England to be zero emissions could further achieve the objectives as set out under s149 of the Equality Act 2010 to:

• eliminate discrimination, harassment, victimisation, and any other conduct that is prohibited by or under the Equality Act 2010
• advance equality of opportunity between persons who share a relevant protected characteristic and persons who do not share it
• foster good relations between persons who share a relevant protected characteristic and persons who do not share it