3. Element 2: Environmental report
3.1. The second part of the consultation sought views on the SEA Environmental Report on the policy plan for an overall 50% reduction in ADT. This section considers respondents’ views on the five consultation questions set out in the consultation document in relation to the Environmental Report. 48 of the 121 submissions (40%) addressed this part of the consultation, in contrast to 97% addressing the policy element.
Views on evidence presented
Q1: What are your views on the evidence set out in the Environmental Report that has been used to inform the assessment process?
3.2. A minority of respondents provided comment on the evidence set out in the Environmental Report; 34 (28% of all responses) responses addressed this question.
Views of those in support of the evidence presented
3.3. Several respondents expressed broad support for the evidence presented by the Report. This included airlines, other transport respondents and environmental organisations.
3.4. These respondents indicated their support for the Report’s assessment of the potential environmental effects of the policy plan, including the focus on carbon emissions, noise and air quality (although some of these respondents also raised potential issues around the evidence presented on these effects). A small number of respondents also specifically noted evidence on the negative environmental impact of this change. A small number of respondents also highlighted the importance of the Post Adoption Statement to be produced following introduction of the policy, as a means of identifying where further assessment is required and in setting out mitigation mechanisms. 
“[Our organisation] feels that the key Assumptions highlighted in the Environmental report are a fair identification of the matters that would need to be considered relating to the environment.” (Other transport and travel organisation)
Issues or concerns raised in relation to the evidence presented
3.5. Most of those providing comment on evidence set out by the Environmental Report identified areas where they felt that the content could be modified or extended. This included several suggesting that the Report could be clearer on what respondents saw as evidence of significant negative environmental impacts associated with the policy plan. A small number of these respondents suggested that this evidence undermined the case for a reduction in ADT.
3.6. Several respondents (primarily airlines and airports) questioned assumptions regarding the likely impact on carbon emissions, and the extent to which these over-estimated the likely impact of the policy plan. This included suggestions that the Report underestimates the potential for improved fuel efficiency, more sustainable aviation fuel, modernisation of airspace, and other on-going initiatives to minimise or offset carbon emissions associated with aviation - for example Sustainable Aviation’s carbon and noise roadmaps, the Carbon Offsetting and Reduction Scheme for International Aviation ( CORSIA) and the EU Emissions Trading Scheme. Some also referred to on-going work to minimise localised environmental impacts.
A number of these responses included detailed accounts of initiatives and evidence relating to these assumptions.
“As highlighted by [organisation name], we believe several elements could be reviewed – including assumptions on the improvement of fuel efficiency of flights, innovation opportunities to accelerate the production and use of sustainable aviation jet fuels, modernisation of airspace, opportunities to improve the management of local impacts such as noise and air quality and the need to consider environmental impacts across the longer term.” (Airline/airline representative)
3.7. Other respondents (other transport, environmental and individual respondents) suggested that the Report underestimates the likely impact of the policy plan on carbon emissions. This included reference to a need to take account of carbon emissions associated with a potential modal shift from rail to air travel as a result of the reduction in ADT, and of the impact of more surface travel to and from airports. A small number of respondents also questioned whether the assessment of the policy’s impact on carbon emissions took account of the “multiplier effect” of carbon emissions at altitude.
“We would urge the Scottish Government to consider the environmental impacts of a modal shift from rail to air and how this would impact on the current shift from air to rail between Scotland’s Central Belt and London.” (Other transport and travel organisation)
“It is not clear whether the Transport Scotland figures take into account the multiplier effect of emissions from aviation at altitude – both the radiative forcing ratio and the uplift factor.” (Environmental organisation)
3.8. Respondents also suggested the following potential modifications to the Environmental Report, including some who wished to see further detail on the potential impact to inform development of secondary legislation:
- A small number of respondents felt that the Report could have included some modelling of the potential impact of alternative approaches to delivering the overall 50% reduction in ADT.
- Several respondents suggested that the evidence set out in the Report should seek to provide an account of the likely longer-term impacts of the policy.
- A small number of respondents suggested that the Report could include a more accurate and detailed account of Scotland’s four main airports, and in particular the extent to which passenger volume and environmental impact are dominated by Edinburgh and Glasgow.
- A small number of respondents suggested that the evidence base for the SEA Environmental Report is unclear (beyond Transport Scotland’s analysis), such that it is not possible to offer a definitive view on the evidence presented.
- A small number of airline respondents suggested there is no link between ADT and the environmental impacts of aviation, and that the tax was not designed to address these impacts.
Views on predicted environmental effects
Q2: What are your views on the predicted environmental effects as set out in the Environmental Report?
Q3: Are there any other environmental effects that have not been considered?
3.9. A total of 39 respondents (32% of all responses) commented on the Environmental Report’s consideration of predicted environmental effects, and/or on the environmental effects not considered.
3.10. A substantial number of these respondents expressed broad support for the Report’s consideration of these effects. This included broad statements of support for the assessment approach, with several respondents specifically noting the negative effects identified by the assessment. Comments also indicated agreement with specific aspects of the assessment such as the extent to which identified environmental effects support a reduction in Band A or Band B flights, localised risks to air quality at airports, and potential negative effects associated with new infrastructure requirements.
3.11. However, the majority of those providing comment raised some areas of disagreement or concern in relation to the identified environmental effects.
3.12. Concerns noted earlier (at Question 1) regarding the extent to which the evidence base overestimates the likely environmental impact of a reduction in ADTwere also reflected in views on the environmental effects predicted by the Report. These were primarily raised by airline and airport respondents, but also included another transport respondent and an environmental organisation. These respondents suggested that the assessment should take greater account of technological developments and other initiatives to limit or offset the environmental impacts of aviation. It was suggested that these developments and initiatives could address the majority of the increase in emissions identified by the Report, and would have a significant impact on emissions beyond 2021 (the Environmental Report considers the period up to 2021).
“[Our organisation] believes that the majority of these additional emissions will be addressed through the EU Emissions Trading Scheme. There may be a small residual amount of additional emissions which are not covered for international (non- EU) flights until the ICAO Carbon Offset and Reduction Scheme for International Aviation, ( CORSIA), commences its voluntary phase in 2021. Beyond 2021 at least 87% of international flights will be captured by this scheme. This scheme will then address any additional carbon emissions above 2020 levels.” (Environmental organisation)
3.13. The extent to which increased aviation demand can be accommodated by existing capacity, without increasing the number of aircraft or flights, was also referenced – it was suggested that “drawing a linear relationship” between increases in passenger numbers and carbon emissions was likely to overestimate environmental effects.
“With the reduction in the Air Departure Tax ( ADT) rates, it is likely that the forecasted increase in passengers will at least partially be accommodated through existing flights, i.e. without an increase in the number of flights but through more passengers being carried on existing flights (higher load factors).” (Airline/airline representative)
3.14. An airport respondent also suggested that a reduction in ADT could encourage more direct travel and reduce additional flights to European hub airports (the respondent suggested that these flights are currently used to transfer through European airports to avoid paying higher rates of tax) and their associated environmental impact. A similar point was raised in relation to potential for a reduction in ADT (if it resulted in lower ticket prices than in England) to encourage more passengers to use Scottish rather than northern English airports, with an associated reduction in surface travel distances for those passengers whose journey begins closer to the Scottish than the English airport.
3.15. A small number of respondents also suggested that the Environmental Report should do more to put the anticipated environmental effects of the policy plan into context. This included reference to the proportion of total Scottish carbon emissions attributed to aviation, and specifically to the anticipated increase in emissions associated with the policy plan equating to 0.19-0.22% of all Scottish carbon emissions.
3.16. As is noted above at Question 1 (in relation to the evidence base for the Environmental Report), other respondents suggested that the Report underestimates the likely environmental impact of a 50% reduction in ADT. These respondents made reference to modelling having been undertaken for the potential for a reduction in ADT to lead to a modal shift from rail to air travel on Edinburgh-London routes, and highlighted the potential for an increase in surface transport to and from airports. Several respondents also felt that the Report should place greater emphasis on the impacts of increased air travel on human health and air quality. It was also suggested that the Report could do more to emphasise what several respondents described as the significant scale of the predicted environmental impacts.
3.17. Other points made by respondents included suggestions that the assessment of environmental impacts should note that any reduction in UK APD (for example in response to the reduction in ADT) could have an impact on the extent to which the policy plan stimulates additional demand for air travel. A small number of respondents also suggested that the Environmental Report could usefully include modelling of the impact of different approaches to deliver the 50% reduction, to inform development of secondary legislation.
“While we…recognise decisions relating to applicability of the tax upon long/short haul flights will be progressed shortly, it would have been helpful for the environmental assessment to explore these scenarios at this point. Assessing such matters at this stage would have potentially provided a fuller picture of the likely environmental effects.” (Environmental organisation)
Views on conclusions and recommendations
Q4: Do you agree with the conclusions and recommendations set out in the Environmental Report?
3.18. The consultation asked whether respondents agreed with the conclusions and recommendations set out in the Environmental Report. The question included a ‘Yes/No’ element, and an opportunity for respondents to explain their view. Table 3.1 below summarises responses to the ‘Yes/No’ question.
3.19. Relatively few respondents gave a view on the Environmental Report conclusions and recommendations; 23 respondents provided a clear view (19% of all responses). These were evenly divided between those in favour (11 respondents) and those opposed (12 respondents). There was no clear difference in the balance of views across respondent types.
Table 3.1: Do you agree with the conclusions and recommendations set out in the Environmental Report?
|Yes||No||No response / Unclear||Total|
|Airlines and airline representatives||1||12||13|
|Airports and airport representatives||5||5|
|Other transport and travel organisations||1||2||3||6|
|Professional tax and accountancy organisations||2||2|
|Group respondents (Total)||3||2||33||38|
|Percentage of all respondents||9%||10%||81%||100%|
|Percentage of those answering question||48%||52%||-||100%|
3.20. A total of 27 respondents (22% of all responses) provided written comment on this aspect of the Report. This included a mix of those who supported the conclusions and recommendations, those who were opposed, and those who did not give a clear view.
3.21. Several of those providing comment indicated their broad support for the conclusions and recommendations set out in the Environmental Report. This included a small number of respondents reiterating points raised in relation to Questions 2 and 3 of this consultation strand, questioning the extent to which the Report may overstate some environmental effects. In contrast, a small number of respondents referred to the conclusions as identifying significant negative environmental effects associated with the policy plan, and wished to see alternatives to a reduction in ADT considered.
3.22. Most of those providing comment at Question 4 identified issues and/or suggested modification to the conclusions and recommendations as set out in the Environmental Report. Again, this included a mix of those who supported the policy plan, and those who were opposed.
3.23. Specific issues and suggestions raised by respondents included:
- Several respondents suggested that the Report’s conclusions overestimate the scale of environmental impact, particularly in relation to carbon emissions. As was highlighted at Questions 2 and 3, these respondents suggested that the conclusion that a reduction in ADT will lead to an increase in the environmental impacts associated with air travel should take greater account of technological advances and schemes to offset and cap carbon emissions.
- A small number of respondents noted that the conclusions and recommendations are focused on short-term environmental impacts, and wished to see an indication of the likely longer-term impacts associated with the reduction in ADT. This included some concern that the Report could give the impression that the policy will only have a short-term impact on emissions.
“As it is currently written, the ER implies that greenhouse gas emissions will increase in the short term only; to rectify this, and to address the uncertainty in the modelling, likely emissions for subsequent years should be given as a range, with an indication of the confidence of the estimates.” (Other organisation)
- A substantial number of respondents suggested that the recommendations are insufficient to achieve the reduction in emissions required to meet the Government’s wider climate change commitments. This included specific reference to targets set by schemes such as CORSIA and the EU ETS as being insufficient – this appears to contrast with views from other respondents, noted earlier, that these schemes will be sufficient to mitigate an increase in air travel. Several of these respondents wished to see a stronger conclusion that the policy plan is not justified.
“The recommendation must surely be that [the Scottish Government] cannot meet…emissions reduction objectives on current assumptions if you permit this ADT reduction to take place.” (Individual respondent)
Other comments on the environmental report
3.24. The consultation invited respondents to provide any other comments on the Environmental Report. Relatively few respondents did so (19 of 121, 16%), and most of these reiterated points raised in relation to earlier questions.
3.25. Specific points raised by these respondents included a suggestion that the Scottish Government should consider opportunities to support innovation around minimising the environmental impact of aviation. It was also suggested that the Environmental Report should take a longer-term view of the environmental effects of the policy plan, and that the assessment should have included a third scenario of zero rated ADT to reflect the Government’s stated ambition to abolish ADT when resources allow. An individual respondent suggested that use of plainer language would have made the report more accessible to the public.
How to access background or source data
The data collected for this social research publication:
☐ are available in more detail through Scottish Neighbourhood Statistics
☒ are available via an alternative route https://consult.gov.scot/fiscal-responsibility/air-departure-tax/consultation/published_select_respondent
☐ may be made available on request, subject to consideration of legal and ethical factors. Please contact <email address> for further information.
☐ cannot be made available by Scottish Government for further analysis as Scottish Government is not the data controller.