Consultation on an overall 50% reduction of air departure tax in Scotland: analysis of responses

An analysis of responses to the Scottish Government’s consultation on an overall 50% reduction plan and environmental report for air departure tax.

1. Introduction

1.1. This report presents an overview of findings from analysis of responses to the Scottish Government’s consultation on an overall 50% reduction plan and an Environmental Report for Air Departure Tax ( ADT). It builds on an initial consultation launched in March 2016 asking how the new tax should be structured and should operate to help achieve the Scottish Government's objective of generating sustainable growth by boosting Scotland's international air connectivity. This included the opportunity to comment on the initial findings and proposed scope and methodology of the Strategic Environmental Assessment ( SEA) that was being undertaken. [2]

The consultation

1.2. The consultation sought views on the Scottish Government’s policy for an overall 50% reduction in ADT by the end of the current parliamentary session, and on the assessment of the likely environmental impacts of the 50% ADT reduction as set out in the SEA Environmental Report.

1.3. Air Departure Tax is due to replace UK Air Passenger Duty ( APD) in Scotland from April 2018, at which point ADT will be collected by Revenue Scotland. Detail of ADT tax rates and bands will be set out in secondary legislation. The consultation was launched on 26 June 2017 and closed on 15 September 2017 with the aim of informing the development of this secondary legislation, and to meet the requirements of the Environmental Assessment (Scotland) Act 2005. The consultation document included two distinct elements: [3]

  • The Scottish Government’s policy for an overall 50% ADT reduction by the end of the current session of the Scottish Parliament - consultation questions focus on the extent to which respondents support the overall 50% reduction and on the most effective way to achieve the reduction across tax bands and rates; and
  • An assessment of the likely significant environmental impacts from the overall 50% ADT reduction policy, with the consultation document summarising the Strategic Environmental Assessment Environmental Report.

1.4. This report presents an analysis of responses to both elements of the consultation.

1.5. In addition to providing an overview of the policy plan, and a summary of the SEA Environmental Report, the consultation document included nine questions where respondents’ views were sought. Four questions were included in relation to the policy plan: one “closed” Yes/No question and three questions inviting written comment. Five questions related to the Environmental Report, all inviting written comment and one question also including a Yes/No element.

Overview of responses

1.6. A total of 121 written submissions were received. This included 38 responses submitted by organisations, 82 submitted by individual members of the public, and one set of campaign responses using standard text developed by the Scottish Green Party. [4] In addition, 37 of the 82 individual responses comprised the standard campaign text with individuals’ own comments added; these have been included in the count of individuals, although they will not be published as full responses.

1.7. A profile of respondents by type is set out in Table 1.1 below.

Table 1.1: Profile of respondents

Number % of all respondents
Airlines and airline representatives 13 11%
Airports and airport representatives 5 4%
Other transport and travel organisations 6 5%
Professional tax and accountancy organisations 2 2%
Environmental organisations 7 6%
Other organisations 5 4%
Group respondents (Total) 38 31%
Individual 82 68%
Campaign 1 1%
TOTAL 121 100%

1.8. Six broad respondent types have been used to categorise group respondents for the main analysis. These respondent types seek to reflect the range of sectors and interests represented by responses, and to maintain consistency with the previous consultation on a replacement to APD. The six categories are summarised below:

  • 13 airline and airline representative respondents included airlines and professional and representative bodies for the sector;
  • Five airport and airport representative respondents included airport respondents and professional and representative bodies;
  • Six other transport and travel respondents comprised a mix of organisations involved in non-aviation travel including those providing travel services, a Transport Partnership, professional and representative bodies, and campaign organisations;
  • Two professional tax and accountancy organisations;
  • Seven environmental organisations included a mix of public bodies, third sector and campaign organisations with a specific environmental focus; and
  • Five ‘other’ organisations representing a range of interests and including representative bodies and third sector organisations.

1.9. Reflecting the range of sectors and interests represented across these respondent types, there was some variation across submissions in their focus on specific aspects of the consultation. For example, all airline, airport, other transport and tax/accountancy respondents answered questions on the policy plan – as did nearly all individual respondents. However, only around half of airline and airport respondents, and less than a third of individuals addressed the Environment Report consultation. In contrast, all environmental organisation respondents answered the Environmental Report, and four of seven addressed the policy plan.

1.10. As noted earlier, a total of 782 campaign responses were received which used standard response text developed by the Scottish Green Party. These were focused exclusively on the policy plan consultation. We highlight in the body of the report where the standard campaign responses addressed specific consultation questions.

Reporting approach

1.11. The remainder of this report presents a question by question analysis of responses given at each of the nine consultation questions across the policy plan and Environmental Report consultations. The report considers views on each of the two elements of the consultation in turn.

1.12. The results of the ‘Yes/No’ questions (question one of the policy plan, and question four of the Environmental Report element) are presented in tabular form. A number of respondents did not make their submission on the consultation questionnaire, or submitted additional free text documents that were not structured around the consultation questions. This material was analysed in relation to the most directly relevant consultation questions or sections, to ensure that the report considered the full range of material provided by respondents.

1.13. Statistical analysis was not appropriate or possible for the qualitative written responses included in submissions. However, in considering the balance of views expressed we use the following reporting conventions:

  • “A small number” to refer to five or fewer respondents.
  • “Several” or “some” to refer to between five and 10 respondents;
  • “A substantial number or proportion” to refer to more than 10, but less than half of respondents.
  • “Most or “the majority” to refer to more than half of respondents.


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