Our statement on Farnborough Airport expansion proposals (23/00794/REVPP)

December 2023

About Possible

Possible is a national charity on a mission to inspire people in the UK to take the action the climate crisis demands. We have produced a wide research base to support our campaigning work on aviation, including reports on a frequent flyer levy, the under-taxing of the high emissions from private jets, and the need to end airline frequent flyer programmes. We also recently published a report with Chatham House, finding that for aviation emissions to stay within the UK’s carbon budget flights will need to reduce by at least a third by 2030.

Our research shows that flying by private jet can be up to 30 times more polluting than standard flights, and that the very low (or in some cases non-existent) taxes on private jets are completely insufficient to effectively manage this. Our research base also makes clear that technological solutions to tackle aviation emissions remain very underdeveloped and often highly speculative, with demand reduction being the first priority.

We oppose this planning permission being granted because of the harm it would cause to the climate. If it is granted, the number of flights at Farnborough Airport would increase, including private jet flights, with resulting negative impacts on the climate.

Outline of the application and context

Farnborough Airport and the growth of the private jet industry

Farnborough Airport is the UK’s and Europe’s largest private jet airport. Our research shows that private jets produce up to 30 times the emissions of a commercial aircraft per person, and so present a serious threat to the climate. Private jets fly at very low occupancy rates, with an average passenger load of just 2.5 to 2.8 people. Within the existing tax system, there are not sufficient incentives to encourage people to stop using private jets. Under the Air Passenger Duty (APD) system, the more polluting an individual’s flight is, the lower the effective rate of tax per tonne of emissions. This demonstrates that private jets are currently the least regulated and taxed flights, despite their disproportionately large emissions profile.

The planning application

A planning application has been submitted to Rushmoor Borough Council to make the following changes, which will significantly increase aircraft emissions if given permission and enacted: 

1. to increase the maximum number of annual aircraft movements from 50,000 to 70,000 per annum, including an increase in non-weekday aircraft movements from 8,900 to 18,900 per annum.

2. to amend the aircraft weight category of 50,000 - 80,000 Kg, to 55,000 - 80,000 Kg, and an increase from 1,500 to 2,100 annual aircraft movements within this category, including an increase from 270 to 570 annual aircraft movements for non-weekdays.

Responses to the application’s Environmental Statement

The main section of the planning application to assess climate change is Environmental Statement Volume I: Main Report: Chapter 9: Climate Change, November 2023, produced by Flightpath 2040 (Farnborough Airport Limited) and available to read in full here.

As Possible is a climate action charity, we will reserve our comments just to this section. The pertinent issues raised by this document and our responses are detailed below.

1. Climate impact of private jets’ contrails
   In paragraph 9.1.7, Farnborough Airport claims that as business jets “normally fly above 41,000ft… contrail formation is not likely to be an issue”. However, research shows that the location of the altitude bands for contrails is quite dynamic and therefore “it would be unfair to assign an aircraft’s cruise altitude as the main driver for a specific flight to be more or less likely to produce contrails. This will primarily be driven by the meteorological forecast on the day.” It is therefore clear that the airport is not properly assessing, reporting, understanding or mitigating the impact of its operations on the climate.

2. Claim that adoption of SAFs reduces emissions by 70%
   Alternative jet fuels or so-called “Sustainable Aviation Fuels” (SAFs) are alternative liquid hydrocarbon fuels that can be used with existing aircraft in place of kerosene produced from fossil fuels. The adoption of SAFs at the UK-wide level is currently at around 2.6%. The UK government has set a target of 10% SAFs by 2030 through the SAF mandate. This means that even at the top-end of estimates, 90% of flights will still be operating with fossil kerosene in 2030, and so still be producing at the very least 90% of their current climate impact at that date. This is without taking into account that the UK government and the aviation industry are also on a trajectory to grow the number of flights during this period. In addition, under Jet Zero Strategy assumptions, SAF is assumed to reduce emissions by 70% when compared to traditional aviation fuel, but estimates on this figure vary, with even the Department for Transport implicitly acknowledging that the actual reductions may be more in the region of 40%.

3. Exclusion of non-carbon greenhouse gas emissions associated with aircraft from the assessment
   The impact of non-CO2 emissions is two thirds of the total climate impact of aviation. It is therefore inaccurate and misleading to remove the damaging effect of non-CO2 emissions from any assessment of climate impact.

4. Predicted GHG emissions in the ‘With Development’ scenario will increase by 24.1% in the period covered by the regional and local carbon budgets
   This is a wholly unacceptable rise in GHG emissions given the climate crisis and the urgent need to reduce emissions. Our research shows that emissions must reduce by at least 36% by 2030 to reach net zero targets, and this expansion would make meeting that target more difficult.

5. “The magnitude of emissions is not likely to be significant and the Proposal does not affect the achievement of the carbon budget.”
   The language being used by Farnborough Airport Limited seeks to underplay the significance of the emissions increase. The cumulative effect of many UK airports proposing to expand at the same time shows the ineffectiveness of current national policy to manage this process and ensure there is not a net negative climate impact.
   
   However, national factors do not remove the responsibility from airports to refrain from bringing forward proposals to increase the quantity of flights and thereby emissions during the climate emergency. Local planning authorities have a right - and, we would argue, a duty - to refuse planning permission based on the negative climate impact that would result.

Conclusion

Farnborough Airport Limited’s proposal to increase flight numbers from 50,000 to 70,000 flights per year is a massive increase in flights. It provides a significant and very worrying signal about how the airport and the private jet operators which use it currently view climate - as an unimportant issue, which is not central to their plans or concerns.

We believe that this is out of step with what the public wants to see. In a Survation poll on behalf of Possible conducted from 15th to 19th June 2023 (sample size: 1,008), it was found that 74% of people agree with the statement that “private jets should be subject to higher tax than commercial flights to reflect their higher emissions”. Further, 43% of people agreed that “private jets should be banned to protect the climate”, with just 24% disagreeing. Although Farnborough Airport does not make policy on aviation, all airports have a role to play in acknowledging the climate crisis, and supporting reduction in aviation emissions through fewer flights.

There has also been significant local opposition to the proposals, with a public demonstration and a petition entitled “Stop expansion of Farnborough Airport” gaining over 4,000 signatures (at time of writing), as well as numerous objections made during the airport’s consultation and on the planning application.

The “market demand” that FAL mentioned in their consultation documents is driven by the aviation industry’s desire to grow at all costs to drive profits, with little consideration of the cumulative climate impact of increasing flights and emissions.

The long-term future of private jet airports such as Farnborough must be an industry-wide investment in developing and delivering electric aircraft for short-haul flights, along with a sharp decrease in the number of private jet flights being permitted in order to fairly reduce unnecessary flying and the resulting emissions.

The “market demand” the airport should be looking to respond to is for fast, efficient, clean and reliable public transport services, and encouraging more people to take the coach or the train rather than polluting flights.

The airport’s proposal to increase the number of its flights during the climate crisis is hugely irresponsible. The airport’s proposal would make it more difficult to achieve net zero emissions in the timescales needed to avert further dangerous and irreversible global warming, which would have serious adverse impacts on the health, livelihoods and lives of people around the world.

We strongly urge Rushmoor Borough Council to refuse this planning application on climate grounds.