Consultation response to the CAA’s call for evidence on consumer environmental information

This paper is Transport & Environment’s (T&E) response to the questions posed by the Civil Aviation Authority’s call for evidence on consumer environmental information. T&E is Europe’s leading clean transport think tank and campaigning group. It was created over 30 years ago and now has staff in 6 countries, with 63 member organisations across 24 countries. It has had a UK office since 2019, working directly with partners and supporting policy-makers with evidence-based solutions to decarbonise UK transport. At the international level, T&E coordinates the International Coalition for Sustainable Aviation, which has observer status at the International Civil Aviation Organisation (ICAO). At the UK level, it is an active member of the Jet Zero Council’s SAF Delivery and Commercialisation groups.   

In 2019, carbon emissions from UK aviation were over 220% of 1990 levels. This is in direct contrast to overall emissions from the UK as a whole, which were 67% of 1990 levels. Furthermore, despite the pandemic it is widely anticipated that they will be back above 2019 levels soon.  A lot of the reason for this lack of decarbonisation progress is the lack of environmental regulation on the industry. Providing consumers with the climate impact of their choices is a simple tool that is already used in other sectors.

The following high level points should be applied to any environmental consumer information:

• Consumers should be provided with environmental information at the earliest point possible in the research and booking process.
• Information should be displayed with the same prominence as the price
• Information should be standardised across all types of booking websites / outlets.
• Non-CO2 impacts should be accounted for.
• The same methodology should be used to calculate the climate impacts of flights, regardless of airline or booking platform.
• For domestic and European flights, the climate impact of taking the journey by car or train should also be displayed. 
• The climate impact of flights should also be compared to the average annual emissions of a British person

Finally, whilst outside the scope of this consultation, consideration should be given to requiring airlines to provide information on the climate impact of flights in any promotional material, akin to how car manufacturers are required to.