Consumer Environmental Information: Consultation on draft principles for aviation consumer environmental information

We consider that the environmental information given to consumers on the emissions of their flight should follow the draft principles set out below, so that information is:

1. Accessible – environmental information should be easily accessible to all consumers wherever flights within, to or from the UK are advertised or sold.
2. Transparent – publishers of environmental data aimed at aviation consumers should publish their methodologies to ensure that it is clear how calculations have been made.
3.  Accountable and accurate – publishers of environmental information are accountable for the accuracy of the calculations and for ensuring the most accurate, up to date and credible sources of input data are used.
4. Specific – environmental information should be calculated using data that is as specific as possible to the passenger’s choice of flight. This means that it should be based on input data that relates specifically to the airline in question (for example, aircraft type, route, seat choice, average load factor, cargo weight proportion etc.). Where specific input data is not available, the most credible alternative data should be used. All sources of input data should be clearly referenced.
5. Timely – the environmental information should be updated regularly to reflect any operational changes that may impact any input used in environmental calculations.
6. Consistent – the same environmental information should be available wherever flights are advertised or sold. Airlines should seek to ensure that, where they publish environmental information related to a flight, that the same information is also available wherever else those flights are advertised and sold. Where third parties publish environmental information related to a flight, they should seek to ensure that it is (as a minimum) aligned with information provided by airlines.
7. Standardised – the publishers of environmental information should meet minimum standards for measuring and reporting environmental data to ensure consistency and comparability between different airlines and flight options.
8. Comparable – environmental information (when using a metric) should be shown using standard metrics – kg CO2 or kg CO2e per passenger journey.
9. Subject to continuous improvement – publishers of environmental information should consider how publishing that information could encourage improvements to aviation sustainability performance and build in mechanisms to measure consumer impacts of publishing this information and enable this information to form part of business improvement decisions.

We consider that the Government’s Environmental Reporting Guidelines would be a suitable framework for Principle 7 on standardisation, but we are seeking views on that principle in this consultation.  
 

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:

1. 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.
2. 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.
3. 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.
4. 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.

Environmental Reporting Guidelines (publishing.service.gov.uk)