January 2025: Opportunity Green wrote a submission to the HM Treasury consultation on the reform of Air Passenger Duty (APD) of private jets. In the Autumn Budget the UK government announced its intention to raise APD on private jets. OG wrote in support of this policy, with recommendations for reforming the APD and going beyond it to decarbonise private jets and aviation in general. The submission highlighted that:

• The UK hosts the second most private jets in Europe, yet up to three quarters are not presently subject to the private jet tax regime.

• The average private jet emits six times more carbon per passenger than the average commercial flight. Depending on the model, private jets produce as much GHG emissions as an average human does in a year in between just one and six and a half hours.

• Depending on plane size and route distance, a private jet passenger may pay the same tax as a commercial plane passenger. The average net wealth of a private jet owner is $1.6bn.

The APD must be expanded to cover all private jets and close loopholes that facilitate tax avoidance. But while reforming the APD is a first step to reducing private jet emissions, the extreme wealth of private jet owners means it is unlikely to act as an effective deterrent on its own. OG therefore recommends HM Treasury works with the Department for Transport (DfT) and Department for Energy Security and Net Zero (DESNZ) to:

• Include a reference to the disproportionate climate effects of the private jet sector in the UK emissions trading scheme (ETS), sustainable aviation fuel (SAF) mandate, CORSIA, and a new zero emission flight (ZEF) mandate.

• Introduce a kerosene tax on commercial and private flights. A £1 per litre tax rate on fuel for private jets could raise up to £200m per year. These measures would help bridge the price gap between fossil fuels and sustainable alternatives, and increase uptake of SAF and ZEF.

• Fund the existing SAF mandate, and a prospective ZEF mandate, with revenues from aviation levies in line with the polluter pays principle, including private jets in higher tax rates.

• Impose taxes on the sale of private jets. Introduce specific mandates obliging their use of e-fuels, as they are the part of the sector that can most bear the cost to allow the e-fuel industry to move from demonstration to adoption across the sector.

• Ensure private jets pay for their pollution and contribute to the general economy by paying fuel tax and VAT as any other sector does.

Read the consultation response in full below.