Air travel is just about the fastest-growing source of climate-heating greenhouse gas emissions. So the Australian government would be stopping the planned worsening of these emissions, due mainly to optional, conspicuous consumption? Well, no actually. by Mark Carter, first published at Pearls&Irritations
On 10 September 2024, federal aviation minister Catherine King gave Melbourne Airport the go-ahead to build a third runway.
Eighteen months earlier, on 10 February 2023, Melbourne Airport’s owner, Australia Pacific Airports Melbourne (APAM) submitted its draft Third Runway Major Development Plan to the Minister, for her approval.
The federal Airports Act specifies what APAM needed to include in its Plan, along with the procedure the Minister is required to follow in assessing the Plan.
Was the airport runway plan even valid?
Section 91 of the Airports Act (1)(h) (j) required APAM to set out its “assessment of the environmental impacts that might reasonably be expected to be associated with the development” together with “its plans for dealing with those impacts, including plans for ameliorating or preventing them.”
While APAM does the assessment, the impacts are not those preferred by the company but those that can be reasonably expected.
An increase in greenhouse gas emissions is one such environmental impact that might reasonably be expected to be associated with a third runway built to enable more flights to and from Melbourne Airport. Without the construction of the runway they wouldn’t be possible.
In fact APAM would appear to acknowledge such emissions. Their MDP states that “Consideration has also been given to ‘indirect’ and ‘off-site’ impacts, in order to ensure a holistic impact assessment of the whole environment, including: ‘Facilitated impacts’ — which result from further actions (including actions by third parties) which are made possible or facilitated by the project. Consideration shall be given to all adverse impacts that could reasonably be predicted to follow from the project, whether these impacts are within the control of M3R or not”.
But the MDP (Ch B11 Table B11.16) then contradicts this claim — to have considered adverse impacts outside its control — by going on to only report those greenhouse gases emitted during landing and take-off (LTO) of third runway enabled flights . These, coincidentally, are a tiny fraction of the ‘off-site’ ‘facilitated impacts’ from full flight emissions.
To justify the exclusion of full flight emissions APAM cites advice from the Airports Council International, “a non-profit association whose prime purpose is the advancement of airport interests” (Ch B11.4.2 p.99). Specifically ACI’s Guideline from 2009, suggests “emissions which an airport operator cannot influence to any reasonable extent” needn’t be counted when completing an airport GHG inventory.
Nonetheless, the Airports Act categorically requires an assessment of all reasonably expected environmental impacts, whether ‘on-site’ or ‘off-site’.
In summary, by failing to assess the environmental impacts of increased greenhouse gas flight emissions, APAM’s draft Major Development Plan was arguably not a valid Plan as defined by Section 91(1)(h) and (j) of the Airports Act.
Insofar as it was an invalid Plan, it was improper of APAM to make it available for public inspection and comment, as required by Section 92 (1) of the Airports Act.
Did the Minister even consider flight emissions impacts?
In deciding whether to approve the Plan, Section 94 of the Airports Act requires the Minister to “have regard to the … impact that carrying out the plan would be likely to have on the environment.” [Airports Act s.94(3)(c)].
APAM’s Plan failed to specify the impact of the significant growth in greenhouse gas emissions likely from the whole of the additional flights generated by the increased capacity of the airport. Nevertheless, did the Minister properly consider these impacts which could reasonably be expected?
Neither the Minister’s Statement of Reasons for Approval, nor the Conditions placed on Approval mention the increase in the emission of greenhouse gases over the lifetime of the development. As such, the Minister appears not to have had regard to them.
In summary, by failing to assess the environmental impacts of increased greenhouse gas flight emissions, as required of her under Section 94(3)(c), the Minister’s approval is arguably invalid.
Why did the minister not acknowledge full flight emissions?
In the face of its climate impacts, why would a Minister not account for full flight emissions in assessing approval of a third runway? Could it be that to do so might undermine the viability of the entire project?
APAM’s MDP reckons the third runway would risk suffering a “Major impact” if the emissions it enabled totalled “0.1% of Australia’s total annual GHG emissions excluding LULUCF”. It states that impact would include “Financial liability [including] capital costs due to implementation of GHG abatement technologies and/or offsetting under a decarbonisation strategy; or financial liability due to [any] future emissions trading scheme and/or carbon tax”. [And] “negative reputation and media attention globally, with follow-on effects including political implications [such that the] project is significantly delayed and/or cancelled.”
So, if the projected annual full flight emissions enabled by a third runway are totalled, are they actually anywhere near that 0.1% threshold?
Let’s do some calculations.
Melbourne Airport reported (p.10) their 2019 LTO emissions were 300,000 tonnes of CO2e. And their full flight (scope 3) emissions were 4,750,000 tonnes. That is, full flight emissions were around 16 times more than those during landing and takeoff.
In 2031 APAM projects additional LTO emissions enabled by a third runway, to be 50,000 tonnes CO2e, and 348,000 tonnes in 2046. Or 0.009% in 2031 and 0.06% in 2046 of Australia’s total annual GHG emissions excluding LULUCF. Assuming they remain roughly 16 times those of LTO, those percentages, for full flight emissions, will balloon to around 0.14% in 2031 and 0.96% in 2046 — exceeding APAM’s own risk of closure threshold.
By its proponent’s own assessment, the Third Runway is at risk of cancellation — if the Minister counted its full flight emissions.
Is the Minister constraining full flight emissions in other ways?
Aviation emissions are back to the pre-Covid annual growth rate of 4%. Yet the Net Zero unit in the Minister’s Department of Infrastructure has set no emissions reduction target for the domestic aviation sector. Not even one that aligns with either of the dangerously inadequate 43% national cut by 2030, or the “Net Zero 2050” goal.
In this deregulated context domestic flight emissions at a three-runway Melbourne Airport are estimated to grow 55% (on 2005 levels) by 2030, and by 83% when international flights are included. Cumulative full flight CO2e emissions from the additional flights enabled by a third runway are estimated to total 40 million tonnes by 2046.
Meanwhile the Safeguard Mechanism counts only emissions from domestic flights by Qantas and Virgin Australia, and requires annual ‘reductions’ of just 4.9%. These are not achieved through actual emissions cuts, but for both Qantas and Virgin Australia through the purchase of carbon credits and by speculatively subtracting the carbon drawn down in growing “Sustainable Aviation Fuel” (SAF) feedstock from the carbon emissions created when the SAF is burnt in flight,.
International flights — 60% of all Qantas flights — face no mandatory emissions cuts. The International Civil Aviation Organisation does “help” member nations develop “the capacity and resources to take action on climate change” through its State Action Plans initiative. But Australia’s 2022 State Action Plan includes no actual inflight emissions cuts. Rather it misleadingly projects “carbon neutral” aviation through the use of SAF.
As long as the level of full flight emissions enabled by an airport is hidden from the public, and in the absence of enforceable, mandated annual reductions across the aviation sector, both airports and aviation emissions will continue to expand.
Flight Free Australia investigated appealing the Minister’s approval on these very issues at the Administrative Review Tribunal. Only the potential six figure legal costs involved prevented us from doing so. Nevertheless, should a federal aviation minister ever prioritise climate safety over aviation growth, the grounds on which airport expansions could be halted are plain to see.
