We have a duty under section 84 of the Civil Aviation Act 2012 (“CAA12”) to publish (or arrange to have published) information and advice we consider appropriate relating to the environmental effects of civil aviation in the UK. We have powers under section 85 of that Act to require third parties to provide information or documents they hold which we reasonably require to carry out our functions under section 84 of the CAA12.
With this duty and these powers in mind, we have considered several options on how these principles could be used to ensure that consumers have access to relevant, accurate, understandable, comparable and accessible information. These options are set out below:
- The CAA publishes the principles as a guidance document, asks airlines and other organisations that sell or advertise flights to follow them and monitors uptake. This option is based on a light touch, voluntary approach.
- The CAA publishes the principles as a guidance document and uses its powers to gather relevant information from airlines and others, which in turn enables the CAA to assess how those organisations are conforming with them and use that information to publish a report on uptake. This reporting could be done through our existing annual reporting of the industry’s environmental performance and could also include verification of the information provided to passengers. This is our preferred option as it incentivises industry to follow the principles without creating an overly complex data gathering and reporting regime.
- The CAA publishes the principles as a policy decision and uses its powers to gather relevant data from airlines. The CAA would then calculate and publish average CO2e emissions for key routes only, using either an existing methodology or developing its own. This more direct approach would provide some limited baseline information to passengers which they could compare to the information provided by the airline or booking agency when searching for and booking a flight. This approach would involve detailed consideration of how that baseline information can be calculated and would require more intensive data gathering and analysis.
- The CAA publishes the principles as a policy decision and uses its powers to gather relevant data from airlines to calculate the carbon footprint of all individual scheduled flights, using either an existing methodology or developing one itself. The CAA could then either publish the information itself and / or ask airlines to publish it with their ticketing/scheduling info. This would be a more intensive approach for both airlines and the CAA that would enable consistency of information across flights booked in the UK but may not be consistent with approaches taken elsewhere.
We consider that options 3 and / or 4 could be taken forward later if our preferred option 2 did not achieve the desired results.
In accordance with section 92 of the CAA12, the CAA must publish a statement of its policy with respect to carrying out its functions under sections 83 and 84, which is currently set out in CAP1143. Should changes to this policy be required to implement the option taken forward, these changes would be consulted on separately in accordance with section 92(5).
The responses to the Call for Evidence showed that the different methodologies currently being used across the industry have both strengths and weaknesses, for example in the data they use, the assumptions they make or the way they are presented. We have not carried out a full analysis of each methodology (some are not publicly available for review) and therefore we do not propose, at this stage, to suggest one that information providers (including the CAA) should follow, nor are we proposing to develop a different methodology ourselves. Our preferred outcome is that the principles and our proposed reporting structure in option 2 will incentivise the industry to work collaboratively on a standard methodology. If we do decide later that either option 3 or 4 are necessary, we would consider the best methodology available for our calculations at that time.
In considering these options, we have also been mindful of work taking place at an international level with organisations such as ICAO, IATA, EASA, airlines, Travalyst and the Google Travel Impact Model.
The CAA is also undertaking other work on emissions calculations and we will update our website as this work progresses.