Additional feedback

While the discussion document set out the key themes linked to the vision for aviation in Scotland, it also made clear that the Scottish Government was open to other ideas on what the Aviation Strategy should try to achieve.

Q23. What else do you think the Aviation Strategy should try to achieve?

Although a large number of respondents responded to this question, many simply reiterated their interests and priorities as noted in response to earlier questions. This included calls for the strategy to set out clear plans for clean energy solutions, phasing out of old non-efficient fleets, investment in/development of short haul electric technology and hydrogen/electric flights, investment in research, development and training and creating a skilled Scottish workforce to support and deliver the changes to aviation that lie ahead.

Noise pollution

Several respondents stated that the absence of any questions or narrative linked to noise pollution was a significant omission and argued that measures to deal with noise should form a central part of the Aviation Strategy:

Any strategy that does not mention [aircraft noise] is not addressing all the issues surrounding aviation. Evidence of the impact of noise on health is gradually accumulating, especially in regard to night noise from aircraft. This strategy should have a clear statement that all measures should be taken to route aircraft away from major population areas even if that resulted in a marginally longer flight path.”
(Individual)

A number of proposals for inclusion in the strategy were posited to help achieve reductions in aviation noise and reduce negative social and health impacts associated with noise pollution (including, for example, monitoring noise pollution and incentivising those in the aviation industry to address it).

Demand reduction

Another key area which several online respondents felt should be given greater attention in the Aviation Strategy was demand reduction and in particular, discussion around what more can be done to make bus, train, ferry, etc. viable alternatives to aviation and encourage modal shift. Reducing overall demand for aviation was seen as key to achieving climate change targets:

Any strategy for aviation, within and to/from Scotland, that does not set out a strategic vision of how much aviation there should be in the future - and demand management policies to achieve such a (reduced) level - is not a coherent strategy. It would also not be consistent with the Scottish Government’s climate change targets and policies.”
(Environmental NGOs/representative bodies)

During workshops, environmental NGOs also commented that the discussion document was lacking a strategic consideration of how much aviation there should be in future and the role that demand management needs to play in reducing aviation emissions. Environmental NGOs also suggested that the Scottish Government should approach decarbonising aviation as it does waste (i.e. reduce, reuse, recycle). Firstly, the government should seek to reduce air travel, then for the air travel which cannot be avoided use low/zero-emission aircraft and finally, for routes where hydrogen/electric aircraft are not feasible, SAF should be used:

The first priority should always be to reduce demand, then use technological innovation to reduce emissions for the remaining flights. This should focus on genuine low-carbon innovation, and should not rely on measures such as offsetting.”
(Environmental NGOs/representative bodies)

Integrated transport network

A third omission noted by a smaller number was the need for the strategy to focus on how the wider public transport system (e.g. bus, rail, ferry) can be better integrated with aviation. Specifically, proposals could be included for how to improve public transport infrastructure to better support travel by air, including access to and from airports, it was suggested:

The Aviation Strategy should explicitly include the Scottish Government’s plans to improve surface transport to ensure sustainable public transport options are included in future investment plans.”
(Business Representative Body)

Other comments

A number of other suggestions from online consultation respondents were given (often presented by just one or two respondents each), and some of these were areas which were already covered in the strategy (suggesting that they were not omissions, but rather areas where more focus may be needed). These included proposals that the strategy should:

consider how more balanced and environmentally efficient forms of taxation can be achieved/sustained longer term (including consideration of how funds raised could be ring fenced to drive decarbonisation of aviation);
ensure that aviation policy prioritises support for those islands/regions where surface transport does not offer a competitive alternative to air links;
include very clear plans for how Scotland will manage Air Passenger Duty and Air Departure Tax going forward;
include details of an aviation restart fund, additional support for route development and financial support for regional airports across Scotland;
explore how to achieve more efficient flight operations/scheduling, including more discussion of the economic role that night flights play within the UK economy and how these could be maintained whilst also meeting noise pollution reduction aspirations;
discuss military aviation, recognising the role that it plays currently in Scotland;
have a greater focus on General Aviation (GA) including potential for investment in research into the economic value of the Scottish GA sector, funding and recruitment of GA apprenticeships, and raising awareness of GA in general;
explore how best to support aviation linked to tourism, including the possibility of having shorter routes to more regional airports;
include plans for supporting and investing meaningfully in route development and Scotland’s international connectivity;
explore airport infrastructure changes to help support the wider aspirations of the Aviation Strategy;
consider the contribution of the outbound travel sector (including outbound leisure) and the value that this produces for the Scottish economy;
consider how to promote/protect passenger safety;
include a focus on maintenance, repair and overhaul;
include plans to tackle idling of aircraft and other vehicles associated with aviation;
explore ways of reducing the burden on public funds/exploration of community inspired private sector investment and development;
ensure that proposed taxation regimes are fair to both regional and more central/larger airports/operators; and
ensure that any infrastructure/supply chain strategy is looked at alongside any relevant UK Government strategy.

Suggestions from workshop delegates were not dissimilar to those raised online and included that:

the Aviation Strategy needed to have a clear vision and be clear on expected outcomes. Delegates stressed that aviation policy cannot be developed in isolation and that full cross-sectoral/ cross-government support was required;
the Aviation Strategy should recognise that different parts of the Scottish Government have a direct or indirect interest in aviation, or make decisions that can affect the future of the sector; and
there needs to be joined up decision making between national government and local authorities on all things linked to aviation including, for example, decisions on access roads to/from airports.

A very specific request was also made for the strategy to set out clear guidelines on plans for COVID-19 recovery with a consistent and co-ordinated approach across the UK:

… aviation’s recovery from the pandemic will be protracted and it will take years to return to pre-pandemic levels. It is imperative that the Aviation Strategy sets out how Scottish Government will better engage with the industry and ensure there is alignment across the four nations in the event we are faced with further variants and
potential restrictions on travel.”
(Aviation and associated industries (including representative bodies))

More general cross-cutting suggestions were to ensure that the Aviation Strategy was inclusive and accessible (especially of the islands and more rural/remote communities and businesses), that there should be greater focus on domestic travel and domestic connectivity across the UK, and that service users were involved in its onward development. Others urged continuous review of evidence and research to inform the strategy, as well as ongoing and systematic consideration of all other relevant policy developments and mandates for aviation to ensure that Scotland’s Aviation Strategy remains congruent and well aligned:

…the Scottish Government should ensure that the Aviation Strategy is aligned to other relevant strategies that have been developed. These include the strategies for tourism, net zero, strategic transport, national planning, trade, inward investment and capital investment.”
(Business representative Body)

Again, several respondents reiterated the importance of the climate crisis and stressed that everything possible should be done in the strategy to assist in meeting emission reduction targets including deprioritising air travel and exploring ways of reducing unnecessary flights, both personal and business related. One respondent specifically expressed disappointment around the lack of reference to the environment in the discussion document.

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