Overview of Comments
The section below sets out a summary of overarching comments relating to the environment. In general, these responses were not submitted to any specific question and were related to the strategic and policy objectives for improving Scotland's air connectivity set out in the policy consultation.
14. A majority of the 161 respondents to both consultations raised some form of environmental concern or objection to the Scottish Government's plans to reduce the APD replacement tax by 50% by the end of the current session of the Scottish Parliament, and abolish it when resources allow. The strategic and policy objectives for improving Scotland's air connectivity were also considered and commented on. Many of these respondents submitted their environmental comments as responses to the policy consultation. Similarly, a number of respondents who submitted views to the SEA Screening and Scoping Report provided comments that directly related to policy proposals and strategic objectives.
15. To ensure that all views have been incorporated consistently within the two analysis reports, this section incorporates these overarching views. These views have been further captured within this document and the analysis report for the policy consultation in instances where the views have been submitted or are related to specific questions.
16. The majority of respondents who did not support the policy proposals referenced the negative effects on climate change as their main reason, stating that reducing or abolishing the APD replacement tax would lead to increased aviation emissions. Respondents commonly stated that the policy aims were inconsistent with Scotland's ambitious climate change targets as set out by or under the Climate Change (Scotland) Act 2009  and the Scottish Government's ambition for Scotland to be a global leader in terms of climate action. A few respondents also referenced the international obligations to reduce greenhouse gas emissions as per the Paris Agreement of December 2015  within their response.
17. Some respondents also referenced the research undertaken by Transport Scotland  in September 2014 that estimated that a 50% reduction in APD could lead to an increase in Scotland's annual CO 2 emissions by the equivalent of between 50,000 and 60,000 tonnes. It was suggested that further independent research should be undertaken to consider the potential effects on carbon emissions of the proposed policy and, on completion, the findings of this be made clear and considered prior to implementation. Furthermore, a few respondents noted that it was not clear which sectors would be required to make an increased effort to reduce their emissions to compensate for the increase in aviation emissions.
18. Respondents also felt that the policy proposals were inconsistent with wider relevant Scottish Government ambitions, such as support for active travel, policy on transitioning to a low carbon economy and the protection and enhancement of the natural environment. For example, the proposals were seen as contrary to one of the ten key behaviours set out in the "The Low Carbon Behaviours Framework"  which encourages the use of alternatives to flying where possible. The wider objectives of "Scotland's Economic Strategy"  , including "protect and enhance our natural capital, our brand and reputation as a country of outstanding natural beauty, our commitment to low carbon and the opportunities our resources and asset provide for our economy and future generations", were also noted.
19. Respondents commented that any APD replacement tax should reflect the environmental impacts of the aviation industry. The Smith Commission Report  recommendation that "the power to charge tax on air passengers leaving Scottish airports will be devolved to the Scottish Parliament. The Scottish Government will be free to make its own arrangements with regard to the design and collection of any replacement tax, including consideration of the environmental impact" was also noted .
20. Whilst a number of respondents noted that APD was not intended to be an environmental tax, they believed there was an opportunity to better design APD and consider environmentally sensitive alternatives, such as measures to help reduce emissions. Similarly, some felt that devolution of APD provided a significant opportunity to use the new tax powers to further the Scottish Government's sustainable development objectives. For example, there was a suggestion that a proportion of the revenue raised by APD could be used to support the delivery of lower carbon, more sustainable modes of transport or other efforts to mitigate climate change, such as peatland restoration.
21. Some respondents felt that the aviation sector should be actively discouraged or restricted due to its environmental effects. Meeting climate change objectives and safeguarding the natural environment was seen as pivotal. This view was also shared by a few respondents who stated they supported the strategic and overall objective of improving Scotland's connectivity, or agreed in principle that Scotland should be better connected, but believed this should not be prioritised over any negative impacts to the environment.
22. Many respondents were of the view that sustainable transport must be prioritised above aviation, (considered to be the most carbon intensive form of transport), in order to reduce Scotland's contribution to climate change. Some added that, in their view, aviation was already under taxed compared to other more sustainable and accessible forms of public transport. There were also concerns that the environmental implications of any modal shifts brought about by a reduction of APD did not appear to be taken account of within the consultation. Many respondents also referred to the Transport Scotland research that concluded that more than half of the increase in passenger numbers that would arise from a 50% APD reduction would come from passengers flying within the UK.
23. Possible implications included an additional increase in long surface journeys being undertaken by those keen to capitalise on lower cost flights. Furthermore, the potential impact on rail journey was noted by some respondents. Concern was raised that applying a reduced rate of APD could have a negative impact through a shift from rail to air, with rail considered as a lower-carbon and more sustainable mode of transport. The important role that rail travel plays as a mode of transport which is more highly compatible with active travel and a greener transport network was also noted.
24. Local level environmental implications arising through aviation activity were noted by a few respondents, for example increased noise and traffic around airports, both of which have health implications. Reference was made to recent trial activity in some airports that sought to expand or change flight patterns and the corresponding complaints that arose due to this. Other respondents drew on personal experience of living within close proximity to an airport. It was considered that these issues would become worse if the APD replacement tax was reduced or abolished; compounding the impacts on already affected local communities. Longer term negative impacts through climate change on health were also noted.
25. Respondents commonly stated that air connectivity should not be considered in isolation but alongside wider objectives, such as those related to tackling climate change, improving public health and quality of life. It was considered that aviation should be one part of a coherent, overarching low carbon strategy, with an emphasis on improving, rationalising and rebalancing Scotland's connectivity, whether by air or by other means. Respondents suggested that the scope and structure of APD could be used to achieve this. This view was echoed by other respondents who felt that the absence of regulatory consistency and policy coherence would undermine efforts across Scotland to reduce GHG emissions.
26. A few respondents reiterated that APD is not an environmental tax and, as such, did not consider this as an effective mechanism to reduce emissions. It was also felt that in some instances a higher rate of APD can lead to passengers traveling via other airports or on connecting flights to avoid incurring the tax, thus leading to increased emissions. It was considered that the contribution of aviation to global carbon emissions should be put into wider context, and be considered alongside existing mechanisms being taken to reduce the environmental impacts, such as the improving efficiencies of modern aircraft.
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