ASA Adjudications

AirportWatch
Broken Wharf House
London
EC4V 3DT
enoughsenough.org Ltd
PO Box 310
Epsom
Surrey
KT17 3YY
Number of complaints: 2
Date: 19 March 2008
Media: National press
Sector: Non-commercial

Ad
A national press ad, for a pressure group, was headed "60% SAY NO TO MORE AIRPORT EXPANSION SO WHY IS THIS GOVERNMENT FLYING IN THE FACE OF PUBLIC OPINION?"  The ad showed a picture of Gordon Brown and stated "An ICM poll this month shows 60% of the public want airport expansion to stop, because of its impact on climate change.  So why won't this government listen? When people want to fly, there's no shortage of choice.  If anything there's too much already.  Why else would airlines be practically giving flights away?  Yet the government is encouraging the biggest expansion of airports the UK has ever seen.  What for? They tell us that aviation already accounts for 13% of UK CO2 emissions - 20% if you include return flights.  They ask us to take climate change seriously and save on energy and resources.  So why don't they? Enough's enough.  Tell Gordon to listen and stop wasting your carbon savings just to fly more planes we don't want.  Send Gordon your copy of this ad at 10 Downing Street..."

Issue
1. easyJet and a member of the public challenged whether the claim "They tell us that aviation already accounts for 13% of UK CO2 emissions - 20% if you include return flights" was misleading and whether it could be substantiated.

easyJet also challenged whether:

2. the claims "60% say no to more airport expansion" and "an ICM poll this month shows 60% of the public want airport expansion to stop, because of its impact on climate change" were misleading, because they misrepresented the results of the ICM survey; and

3.  the claim "Yet the government is encouraging the biggest expansion of airports the UK has ever seen" was misleading and whether it could be substantiated.

The CAP Code:  3.1;7.1;49.1;49.3

Response
AirportWatch and enoughsenough.org submitted a joint response.

1. They provided a statement given by Gillian Merron, Parliamentary Under-Secretary, Department for Transport (DFT) in the House of Commons, which stated "Using a radiative forcing multiplier of two, emissions from flights departing the UK contributed to approximately 13% of total UK emissions in 2005".  Airportwatch said the percentage increased to 20% if flights returning from the UK were included.

2. AirportWatch and enoughsenough.org provided a statement from Woodnewton Associates (Woodnewton), the company that managed and designed the research project for the ICM poll.  Woodnewton said the relevant question asked in the poll was "Based on what you have seen or heard about the impact of climate change, do you think it is a good idea or a bad idea for Government to increase the capacity of the number of flights allowed at UK airports?"  They said that in response to that question 28% said it was a very bad idea and 32% said it was a fairly bad idea.  They said the reference to "airport expansion" used in the ad was acceptable shorthand for "the increase in the capacity for the number of flights" and it was not open to misinterpretation.  They said airport expansion was both a matter of the physical area taken up by the airport itself, the capacity of the physical infrastructure and any expansion or increase in the number of flights and/or their environmental impact.  They therefore believed there was no meaning in the phrase "the increase in the capacity for the number of flights" that was not also contained in the phrase "airport expansion".  They said it was common practice in opinion polling to use "Likert" scales (for example support/oppose or good idea/bad idea) to assess public attitudes and for the results to be presented in language closer to that used in everyday conversation or public debate. They therefore believed it was not misleading to suggest that those who said expansion was a 'bad idea' would also like that expansion to be stopped.  They said, for example, polls on public attitudes to the 2003 invasion of Iraq showed that the majority 'opposed' the invasion (based on the support/oppose Likert scale) and those results were regularly reported to show the majority wanted the invasion to 'stop'.

3. AirportWatch and enoughsenough.org provided several documents from the DFT, for example the 2003 Future of Air Transport White Paper, which reported the Government's proposals for airport expansion. They said those sources demonstrated that the Government had identified 30 airports which were either suitable for significant development or which were forecast to have a minimum of 20,000 air transport movements in 2030.  They said Government policy provided encouragement to airport owners, airline owners, local planning authorities and others to expand airports and airport capacity.  They said the airport capacity increases envisaged by the Government would cater for over double the 2003 level of passengers by 2030.  Therefore, in terms of total passengers, they said there was a greater increase forecast for the period 2003-2030 than occurred during the period 1945 - 2003, which made it the largest airport expansion ever seen in the UK.

Assessment
1. Upheld
The ASA noted AirportWatch and enoughsenough.org had taken the 13% figure from a statement given by the DFT Parliamentary Under-Secretary in the House of Commons.  However, we noted the full quote stated "In 2005 aviation represented 6.3 per cent of UK emissions ... As the 'Future of Air Transport Progress Report' (December 2006) noted, aviation emissions arising from the combustion of kerosene include carbon dioxide, water vapour, nitric oxide and nitrogen dioxide, particulates and other compounds. These give rise to 'radiative forcing' impacts. The total radiative impacts were estimated by the EC TRADEOFF project to be approximately twice those of carbon dioxide (excluding cirrus cloud formation). Using a radiative forcing multiplier of two, emissions from flights departing the UK contributed approximately 13 per cent of total UK emissions in 2005".   We noted many different figures were available for aviation's contribution to climate change, including CO2 emissions specifically or the overall impact of aviation emissions on climate change (which included the multiplier effect of radiative forcing).  We understood that the impact of radiative forcing was uncertain and there was no internationally agreed method of measuring its impact, which meant it was not included in national emissions totals reported to the Intergovernmental Panel on Climate Change (IPCC) as part of the Kyoto Protocol.  Although we acknowledged that the UK Government had quoted the 13% figure which included a radiative forcing impact, we noted they had also quoted a figure without that multiplier and we therefore considered that, to avoid confusion, it was important that the basis of the figures quoted in the ad was made clear.  We concluded that the claim should have made clear that the 13% figure included a multiplier for the radiative forcing impact.  

We noted the claim also stated "20% if you include return flights" and that the statement made in the House of Commons had not referred to that figure.  We considered that, because the claim stated "They tell us", readers were likely to infer that both the 13% and the 20% figure had been publicly stated by the Government.  We noted there was no agreed method of attributing international aviation emissions to specific countries and that international aviation emission figures were therefore not included in the national totals reported to the IPCC.  We noted the UK Government, nevertheless, chose to report figures for international aviation based on calculated emissions from domestic flights and from international flights departing the UK only.  We therefore noted the 20% figure went beyond the UK Government's approach for measuring aviation emissions specific to the UK and was based on AirportWatch and enoughsenough.org's own calculations of aviation emissions.  We considered that AirportWatch and enoughsenough.org had not demonstrated that the 20% figure had been publicly stated by the Government and therefore the ad should have made clear that the figure was based on their own emissions calculations.  

We concluded that, because the ad did not make the basis of the quoted figures clear, and because it implied the 20% figure had been publicly stated by the Government, it was likely to mislead.

On this point the ad breached CAP Code clauses 3.1 (Substantiation), 7.1 (Truthfulness), 49.1 and 49.3 (Environmental claims).

2. Upheld
We noted the claim "60% of the public want airport expansion to stop" was based on responses to the question in the ICM poll "Based on what you have seen or heard about the impact of climate change, do you think it is a good idea or a bad idea for Government to increase the capacity of the number of flights allowed at UK airports?".  We noted 32% had stated it was a "fairly bad idea" and 28% a "very bad idea".

We considered, however, that readers were likely to understand from the ad that 60% of respondents to the poll had specifically stated that they wanted airport expansion to stop.  We considered that the fact that a majority of respondents thought that increasing airport capacity was not a good idea because of its environmental impact did not necessarily mean that they wanted airport expansion to stop, because, respondents might, for example, have considered that the economic benefits of airport expansion outweighed the environmental impacts and therefore they would have been unlikely to have answered that they "wanted airport expansion to stop". We concluded that the claims misrepresented the results of the survey and were therefore likely to mislead.

On this point, the ad breached CAP Code clause 7.1 (Truthfulness).

3. Upheld
We noted AirportWatch and enoughenough.org highlighted several papers, which outlined the Government's expansion plans for UK airports and specifically referenced 30 airports which had either been identified for significant development or which were forecast to have a minimum 20,000 air transport movements in 2030.  We also noted their assertion that the airport capacity increases envisaged by the Government would cater for over double the 2003 level of passengers by 2030.  However, we consider readers were likely to interpret "airport expansion" as a reference to more than merely the number of passengers using the airports.  We considered that they were likely to infer that the claim was also based on other factors, for example the area taken up by airports or the number of runways.  We acknowledged that the evidence highlighted by AirportWatch and enoughsenough.org demonstrated that the Government was encouraging some airport expansion but we considered that that was insufficient to support the claim that the expansion plans outlined in those papers constituted the "biggest expansion of airports the UK has ever seen".  Because we had not seen evidence to demonstrate that the Government was encouraging the "biggest expansion of airports the UK has ever seen", we concluded the claim was likely to mislead.

On this point, the ad breached CAP Code clauses 3.1 (Substantiation) and 7.1 (Truthfulness).

Action
We told AirportWatch and enoughsenough.org not to repeat the claims "They tell us that aviation already accounts for 13% of UK CO2 emissions - 20% if you include return flights", "60% say no to airport expansion" and "the government is encouraging the biggest expansion of airports the UK has ever seen" or any similar claims.  We told them to ensure that they had sufficient evidence to support their claims and to make the basis of their claims clear in future.  We advised them to contact the CAP Copy Advice team for guidance on their future advertising.

Adjudication of the ASA Council (Non-broadcast)

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