Consultation on an overall 50% reduction of air departure tax in Scotland: analysis of responses

Executive Summary

This report presents an overview of findings from analysis of responses to the Scottish Government’s consultation on an overall 50% reduction in Air Departure Tax ( ADT) and the Strategic Environmental Assessment ( SEA) Environmental Report. ^[1] A total of 121 responses were received. This included 38 submitted by organisations, 82 submitted by individual members of the public, and one set of campaign responses using standard text developed by the Scottish Green Party.

Support for the 50% reduction in ADT

A minority of respondents supported the policy plan (30 of 121, 25%), although the majority of group respondents were in favour. Comments from those who support the policy plan were focused primarily on potential for the reduction in ADT to improve Scotland’s connectivity. Key points raised included:

• Evidence indicating that Scotland has poor air connectivity relative to other parts of the UK and Europe, and suggestions that a reduction in ADT could help Scotland to be more competitive.
• Suggestions that air connectivity has an important role for Scotland’s tourism industry and wider economic growth, and estimates of the likely positive economic impact of a 50% reduction in ADT for Scotland.
• More specific benefits including to existing routes which operate on “thin margins”, and which are important where surface travel options are not practical.

Opposition to the 50% reduction in ADT

The majority of respondents did not support the policy plan; 85 of the 121 submissions (70%), including a large majority of individuals. Key points raised by these respondents included:

• Evidence highlighting the likely environmental impact, particularly the increase in carbon emissions linked to an increase in air travel - on this basis, some suggested that the policy was inconsistent with the Scottish Government’s climate change commitments.
• Some described the 50% reduction as a “regressive” proposal which will primarily benefit businesses and higher income households.
• Reference to the risk of reduced government revenues, and a preference to retain this income to support infrastructure/services.
• Potential for the reduction in ADT to have a negative impact on other, lower carbon transport modes (particularly rail travel).
• Questioning the extent to which the policy would deliver the anticipated benefits, including suggestions that this was more likely to benefit outbound travel rather than inbound tourism.

Achieving the overall 50% reduction

Respondents commenting on specific options to achieve the 50% reduction in ADT included a mix of those who supported the policy plan, those opposed, and those offering no clear view. These respondents expressed support for a range of approaches:

• Support for a “flat” 50% reduction across current tax bands/rates was related to as being the simplest means of delivering the 50% reduction, and with the benefit of consistency with the structure of UK Air Passenger Duty ( APD), including avoiding additional costs to adapt systems.
• Support for targeting the reduction at short-haul flights included suggestions that: this approach would deliver the greatest benefits; reference to short-haul routes accounting for the large majority of air travel to and from Scotland; suggestions that demand is more sensitive to pricing; and suggestions that a reduction in ADT could have a greater impact in development of new routes.
• Support for a targeted reduction for long-haul flights included suggestions that: current rates for these journeys are disproportionately high; this could improve connectivity with new markets outside the European Economic Area; and, reference to evidence of higher spending by long-haul passengers.
• Respondents suggested a range of other approaches to deliver the overall 50% reduction including: a targeted reduction for reduced rate passengers; a 100% reduction in ADT for intra-Scotland air travel; and, a reduction in ADT linked to the carbon impact of flights.

Views on environmental evidence

A minority of respondents (34 of 121, 28%) commented on the evidence set out in the SEA Environmental Report. Several of these respondents expressed broad support for the evidence, and in particular agreed with the focus on carbon emissions, noise and air quality as the key environmental effects. However, most of those providing comment identified areas to be modified or extended:

• There were suggestions that the Report could be clearer on what was seen by respondents as evidence of significant negative impacts, with some stating that this evidence undermined the case for the policy.
• There were suggestions that the Report underestimates potential for technological developments and other ongoing initiatives to minimise or offset carbon emissions associated with aviation.
• There were suggestions that the Report does not take sufficient account of carbon emissions associated with a potential modal shift from rail to air travel, nor of the impact of more surface travel to and from airports. There was also a suggestion that the Report should seek to provide an account of the likely longer-term impacts.

Views on predicted environmental effects

Several of those commenting on the predicted environmental effects expressed broad support for the Report’s consideration of these, but most of those providing comment raised issues:

• There were suggestions that the Report overestimates the likely environmental impact of a reduction in ADT, including a view that technological advances and schemes to cap or offset carbon emissions could mitigate the majority of the predicted increase in emissions.
• There were suggestions that the Report underestimates the likely environmental impact. This included respondents noting that the Report does not take account of a potential modal shift from rail to air travel, the impact of surface transport to and from airports, and impacts on human health and air quality.
• Other points included suggestions that the assessment should take account of the potential for a reduction in UK APD in response to the policy plan, and modelling of different approaches to deliver the 50% reduction to inform development of secondary legislation.

Views on environmental conclusions

Respondents offering a view on the SEA Environmental Report conclusions and recommendations were evenly divided between those in favour (11 respondents) and those opposed (12 respondents). Most of those providing written comment identified issues or suggested modifications:

• There were suggestions 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.
• There were suggestions that the recommendations are insufficient to achieve the reduction in emissions required to meet the Government’s wider climate change commitments.
• There were suggestions that the Report should include an indication of the likely longer-term impacts of a reduction in ADT.