GREENAIR NEWSLETTER 15 JANUARY 2016
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Reports from IMF and French economists call for climate taxes on international aviation fuel or air travel
Fri 15 Jan 2016 – Two reports, one an International Monetary Fund (IMF) internal discussion note and the other by the Paris School of Economics (PSE), suggest taxing international aviation fuel or air travel could provide an equitable solution to raising global finance for climate mitigation and adaptation. The IMF says there is an immediate need for governments to follow up the Paris Agreement reached last month with fiscal policies that put carbon pricing “front and centre” in efforts to reduce carbon emissions. Substantial amounts – upwards of $25 billion – could be raised from charges on international aviation and maritime fuels, says its discussion note. The PSE paper by Lucas Chancel and best-selling author Thomas Piketty estimates a €180 ($200) levy on business class tickets and €20 ($22) on economy class would raise around €150 billion ($165bn) a year for climate adaptation. However, an effort to include a call for a levy on the aviation and shipping sectors was rejected by countries in the lead-up to the Paris climate negotiations.
After the successful outcome of Paris COP21, IMF Managing Director Christine Lagarde said the agreement was “a critical step forward for addressing the challenge of global climate change in the 21st century” and now governments had to put words into practice by implementing policies to effect the mitigation pledges they had made.
“That is why my key message is to price carbon right and to do it now,” she commented. “Charging for the emissions of fossil fuels puts in place the needed incentives for low-carbon investments; it also provides revenues to safeguard the poor, reduce debt, and lower the burden of other taxes on households and businesses.”
Carbon pricing through taxes or trading systems designed to behave like taxes, defines the IMF, are potentially the most effective mitigation instruments, are straightforward to administer, raise timely revenues and establish the price signals that are central for redirecting technological change towards low-emission investments, says its staff discussion note. In addition, carbon pricing in developing countries would establish price signals needed to attract private flows for mitigation.
International aviation and maritime fuels are a growing source of emissions, are underpriced and charges would exploit a tax base not naturally belonging to national governments, say the IMF authors. They note that tourism, one of the beneficiaries from air and sea transport, will be impacted by exposure to climate change and related extreme weather events. They argue different patterns of tourism flows at the regional level will be created, resulting in losses for most developing countries, while high-latitude advanced economies would gain.
Charges on “rapidly rising” international emissions from the aviation and maritime sectors are a promising source of climate finance, says the paper. The need for international coordination is a challenge, it admits, as are the legal issues in the case of aviation due to treaties (the Chicago Convention) and bilateral air service agreements that limit fuel taxes. “But the practicalities should be manageable,” it contends.
The IMF researchers estimate a global $30 per ton CO2 charge on international fuels from the two sectors could have raised around $25 billion for climate finance in 2014, even after compensation for developing countries.
The PSE study examines the global distribution of greenhouse gas emissions (CO2e) between world individuals from 1998 (the Kyoto Protocol dates from 1997) and 2013, and comes up with different scenarios and strategies for contributing to a global climate adaptation fund based on efforts shared among high emitters rather than high-income countries. The study shows that inequalities between individuals in terms of global GHG emissions has decreased since Kyoto due the rise of top and mid income groups in developing countries and the relative stagnation of incomes and emissions of the majority of the population in industrialised economies. Over the period, however, income and GHG emissions inequalities have increased within countries.
The two economists estimate the top 10% emitters contribute to 45% of global emissions, while the bottom 50% contribute to just 13% of global emissions. These top 10% emitters live on all continents, with one third of them from emerging countries. The middle and upper classes of emerging countries increased their GHG emissions more than any other group within the past 15 years. In addition, there is now a greater inequality between the bottom of the distribution and the middle.
“While these trends, if continued, are positive from an income point of view – the emergence of a global middle class – they constitute a real challenge for future global CO2e emissions levels,” they say.
“Our estimates also show that within-country inequality in CO2e emissions matters more and more to explain the global dispersion of CO2e emissions. In 1998, one third of global CO2e emissions inequality was accounted for by inequality within countries. Today, within-country inequality makes up 50% of the global dispersion of CO2e emissions. It is then crucial to focus on high individual emitters rather than high emitting countries.”
The report suggests strategies to increase global climate adaptation funding, in which individual CO2e emissions, rather than national CO2e or income averages, are the basis for contributions. One of these scenarios is through a generalised progressive tax on air tickets. This might prove the easiest solution to implement, argue Chancel and Piketty, although less well targeted at top emitters.
The effort-sharing in contribution would be borne largely by air passengers in North America (29.1%), EU (21.9%) and China (13.6%).
ICAO and the aviation industry has resisted calls for the sector to contribute through a levy to climate finance. The governing ICAO Council issued a Declaration that was circulated at COP21 calling for international aviation not to be targeted as a revenue source “in a disproportionate manner” (see article).
“There have been a number of calls for global air transport revenues to be taxed by States for use in non-aviation-related climate change mitigation programmes,” said Council President Dr Olumuyiwa Benard Aliu. “The ICAO Council, through this Declaration, wished to stress very clearly … that this is an unfair approach and one which is ultimately counter-productive given the historic and exemplary environmental performance of our sector and the significant socio-economic benefits it brings to States and Regions all over the world.”
At the industry’s Global Sustainable Aviation Summit in Geneva last September, Michael Gill, Executive Director of the Air Transport Action Group (ATAG), said using aviation as a source of climate finance would hit hard those countries, particularly developing and small island states, heavily reliant on air transport for their connectivity and economy (see article).
“Such a blunt instrument will not have any measurable environmental benefit,” he told delegates. “Therefore, we will continue to insist that a global market-based measure developed through ICAO is a way to not only ensure fair distribution of responsibility, but also environmental integrity and financing to climate projects all over the world.”
IMF – ‘After Paris: Fiscal, Macro-economic, and Financial Implications of Climate Change’
PSE – ‘Carbon and inequality: from Kyoto to Paris’
Aircraft operators rack up over $1 million in UK penalties for non-compliance with EU ETS in 2012
Thu 14 Jan 2016 – Following the civil penalties handed out to five aircraft operators last June (see article), a further 18 operators of corporate or VIP aircraft and two airlines have been issued with penalties for failing to surrender sufficient EU ETS allowances in time to cover their intra-EEA flights in 2012. Among the latest to be fined are 21st Century Fox America, formerly known as News America Inc, the Bahrain royal family, and entrepreneur and US presidential candidate Donald Trump. The largest fine, £157,596 ($228,000) has been levied on British construction equipment manufacturer JCB in respect of flight emissions totalling 1,931 tonnes of its Gulfstream G650 aircraft. With the exception of Air India, whose fine from last year remains unpaid, most of the operators listed have now come into compliance.
The EU directive that underpins the Aviation EU Emissions Trading System (EU ETS), which came into effect in 2012, mandates the EU state that operators report to must issue a €100 per tonne penalty for any shortfall in allowances not surrendered by the end of April in the following year.
On top of the fine, the operator is still required to purchase and surrender the requisite number of allowances to cover reported emissions. Fines or civil penalties can also be levied for failing to submit an application for an emissions plan or monitor aviation emissions (in the UK, up to £1,500 and £150 per day outstanding), plus up to £3,750 and £375 per day for failure to report aviation emissions. The UK government has so far declined to reveal whether such penalties have been issued to any operator.
Barry Moss, CEO of aviation risk management company Avocet, reports civil penalties for these failures remain relatively low and are capped at around £63,000 ($91,000) for all offences, whereas in Spain, for example, the civil penalties can be as high as €2,000,000 ($2.17m) per offence. “From our experience, the Environment Agency, which administers aircraft operators reporting to the UK, makes every effort to encourage delinquent operators to comply and so far it has been more carrot than stick,” he said. “The enforcement of such penalties is also discretionary.”
Along with the five operators fined last year, the 20 added to the list last week brings the level of civil penalties handed out by the UK for failing to surrender the correct allowances for the first year of the Aviation EU ETS to £757,534 ($1.1m).
Also on the latest list of operators that carried out flights during 2012 between airports within the European Economic Area (EEA) – which includes EU states plus Iceland, Liechtenstein and Norway – and failed to surrender allowances by the 30 April 2013 deadline is Brazilian aircraft manufacturer Embraer. It was fined £52,136 in respect of 615 tonnes of carbon emissions during that year.
The comparatively modest fine of £1,610 handed to the operator of Donald Trump’s ‘Trump Force One’ Boeing 757-200, DJT Operations I LLC, was in respect of allowances not surrendered to cover 19 tonnes of carbon emissions in 2012. According the EU Transaction Log, Trump has since come into compliance with EU climate regulations and has also surrendered allowances for flight emissions of 60 tonnes from his VIP jet within Europe in 2014.
The two airlines included in the latest batch of civil penalties issued by the UK government are flag carrier Turkmenistan Airlines and Jet Airways of India. The latter appealed twice against its fine of £12,716 on the grounds that the Indian government had instructed it not to comply with the EU climate scheme (see article). Having failed on each occasion to convince an independent adjudicator, Jet Airways has since paid the fine and is now in full compliance for the years 2012-2014. Turkmenistan Airlines, which was fined £10,766 in respect of 127 tonnes of carbon emissions during 2012, is also now in full compliance for the three years.
However, flag carrier Air India, which was issued with a £12,277 civil penalty last June, has neither paid it nor come into compliance. Russia’s state-owned Aeroflot, which reports to Germany, has also yet to comply with the EU regulation. Although Saudi Arabian Airlines has paid a sizeable fine to the Flemish authorities over its intra-EEA emissions in 2012 (see article), it has yet to come into compliance. Due to political sensitivities, particularly in the run-up to the global COP21 climate talks last month, EU states have so far appeared reluctant to take on flag carriers from countries that were key to the negotiations.
As a result of significant changes in reducing the scope of the EU ETS in early 2014, the directive was amended so that operators could report their emissions and submit the required allowances for both 2013 and 2014 together in early 2015. Operators are now due to report their 2015 emissions by 31 March and surrender allowances by 30 April.
UK list of Aviation EU ETS civil penalties
European Commission – Aviation EU ETS
Heathrow sets out progress on action plans to reduce noise, emissions and traffic as it pledges to “go electric”
Wed 13 Jan 2016 - With air quality around Heathrow a major stumbling block to expansion, the airport has signalled its ambition to “turn Heathrow electric” and shift more vehicles used on and around the airport to electric power. It has given the go-ahead to install 135 more chargers for over 260 electric vehicles at a cost of £2 million ($2.9m), as well as roll out initiatives to encourage greater use of public transport for passengers and airport staff. In efforts to “make an expanded Heathrow the most environmentally responsible hub airport in the world”, CEO John Holland-Kaye has outlined a progress report on plans and commitments “that will make us a better neighbour, by reducing noise, emissions and traffic.” Heathrow says penalties on older aircraft will see it becoming the first large European airport to be free of the noisiest Chapter 3 aircraft.
Heathrow has published three blueprints over the past year setting out a series of action plans on how the airport will reduce noise, emissions and traffic. Against each of the commitments it has provided an update in the form of a traffic light rating – red, amber or green – with supporting commentary. The airport says 70% of the promises have been put into action and the remaining 30% are in progress, with none not yet started.
“We are providing an update on the very significant progress already been made, thanks to the commitment of the airport community,” said Holland-Kaye. “But we know that we need to do more, and in the coming months will set out even more ambitious plans.”
On night-time noise, Heathrow reports the number of disrupted schedule flights that take-off after 23.30 has almost halved over the past year, with the trend set to continue, it predicts. This year it will work with NATS to make respite from aircraft noise more predictable for residents, especially between 04.30 and 06.00, by setting a target for meeting first preference runways during night-time alternation. Currently first preference runways are utilised 50% of the time but this could be increased greatly, claims Heathrow.
Heathrow’s latest ‘name and shame’ Fly Quiet Programme League Table, introduced two years ago, indicates a greater use of the Continuous Descent Approach (CDA) flight procedure by airlines serving the airport. The airport contacted eight of the worst performing airlines last year and reports “significant improvements” from five of them. In 2014, 85% of daytime and 90% of night-time arrivals achieved a CDA, although overall performance only marginally improved during 2015, it admits.
Following a study in 2014 and a subsequent follow-up in 2015 on when approaching aircraft deploy their landing gear, which adds to noise levels, the airport has undertaken efforts with airlines to minimise unnecessary early deployment. This is one of the few areas that is flagged amber in the report as performance remains similar, although it has had some successes. A third study is planned this year to monitor progress and explore how the analysis could be automated.
A trial of slightly steeper aircraft approaches – 3.2 degrees instead of 3 degrees – started in September 2015 with the participation of around 20 airlines and is due to complete in March 2016. Noise monitors have been deployed and Heathrow plans to produce a report by the middle of the year.
Another noise issue that has plagued residents is the high-pitched whistle produced by the Airbus A320 family of aircraft, created when air passes over fuel tank vents just before landing gear and flaps are deployed for landing (see article). The aircraft type makes up about 50% of all traffic movements at Heathrow but only around 5% are fitted with the vortex generator component that is designed to minimise the noise. However, Heathrow says airlines will be accelerating the retrofit of the device over the next 18 months. Airlines currently implementing retrofit programmes include British Airways, Lufthansa and Air France.
Fines for breaking noise limits have been significantly increased, says Heathrow, and the number of infringements in 2015 has continued to fall. The new regime is a per dB scheme where daytime infringements incur £500 ($720) per dB, night shoulders £1,500/dB and night-time £4,000/dB.
Last month, Heathrow announced it had made available nearly £250,000 ($360,000) in funding for local environmental projects in the five boroughs neighbouring the airport under its Heathrow Community Fund. The Fund is supported by an annual donation by Heathrow Airport and income generated from aircraft noise fines.
Attempting to phase out the oldest and dirtiest aircraft from using the airport, Heathrow has increased the NOx element of its total environmental charge from 15% to 20%, with the price per kg of NOx nearly doubling from £8.57 to £16.51 ($24). The proportion of aircraft meeting the best international emissions standard (ICAO CAEP 8) at Heathrow grew by 1.5% from 2013 to 2014, with more new aircraft introduced in 2015, and updated results are due to be published this quarter.
Heathrow is consulting with airlines on how emissions-related measures can be included in its Fly Quiet League Table and plans to introduce them in early 2016 in parallel with a revised Fly Quiet Programme timeline.
The airport has implemented a number of strategies for reducing emissions from the use of aircraft APUs at the gate. Pre-conditioned air (PCA) and gate power consumption in 2015 was 60% higher in 2015 compared to the previous year, against a target of 15%. In October 2015, Heathrow committed to investing £16.2 million ($23.3m) in upgrading PCA systems from summer 2016. The percentage of aircraft complying with APU running time limits is now at 89% against a target of 85%.
To improve taxiing efficiency, a new automatic measure of the use of reduced-engine taxiing (RET) on eligible departures (defined as those that do not require a runway crossing) was introduced in the air traffic control tower during 2015, which recorded about 25% of departures using the procedure. A plan is in place to monitor RET on arrival by the end of this quarter. There has been a marginal improvement in the use of RET on departure over the year but as reporting has been inconsistent, more work will be done to make it easier for pilots to report when using RET, says Heathrow.
During 2015, Heathrow reports that it undertook a detailed study into the use of the TaxiBot pilot-controlled towing tractor that tows aircraft close to the take-off point without significant running of the engines. Use of TaxiBot is being considered for the future but cannot be immediately implemented due to space constraints at the airport, it says, and adds it is working with airlines to investigate the use of electric taxiing systems built into the aircraft nose wheel.
Visitors using the short-stay car parks can now access free of charge 21 electric vehicle charging points and, in 2015, 13 charging points were upgraded in Terminal 2’s short-stay. Monthly reporting shows an increase in usage since last October. A publicly-accessible hydrogen refuelling station is also based at Heathrow and zero-emission vehicles are being added to Heathrow Airport’s fleet of 400 vehicles, supported by a £250,000 investment in electric vehicle charging infrastructure during 2015. Talks with Transport for London have started to investigate using the Heathrow Feeder Taxi Park as a trial site for electric hybrid taxi charging.
According to Heathrow, road traffic to the airport has remained largely static whilst overall passenger numbers have increased. In 1991, 40.5 million passengers created a total of 45.4 million car trips, whereas in 2014, passenger numbers totalled 73.4 million resulting in 46.7 million car trips.
A new £1 million local transport fund has been created for projects to reduce congestion, such as supporting bus routes, with new 24-hour bus services serving the west of the airport beginning in 2015 for airport employees. Heathrow – the UK’s largest single-site employer – already has the country’s largest car-share network and in 2016 a new app will be launched to make car share even easier. A new cycle plan for employees living closer to the airport will be launched shortly, following the opening in 2015 of a new ‘cycle hub’ that provides bikes and equipment for hire and sale.
The three blueprints will be reviewed, revised and republished during 2016, pledges Heathrow.
Heathrow Airport – Blueprint action plans and updates
End of an ERA: NASA completes six-year research programme to reduce aviation’s environmental impact
Thu 7 Jan 2016 ‒ NASA’s Environmentally Responsible Aviation (ERA) project to research and develop green-related technologies that could reduce aircraft emissions and noise has come to a close. Over the course of the six-year project, NASA had invested more than $400 million, with a further $250 million in-kind resources contributed by industry partners. The new technologies developed and refined by NASA’s aeronautics researchers could help US airlines realise over $250 billion dollars in savings in the near future, claims the agency. Goals for the project included reducing aircraft drag by 8%, aircraft weight by 10%, and cutting specific engine fuel consumption by 15%, engine NOx emissions by 75% and aircraft noise to nearly one-eighth of today’s standards by 2025.
The ERA project focused on eight integrated technology demonstrations that were completed by researchers and industry partners, including:
- Tested using Boeing’s ecoDemonstrator 757 flying laboratory, tiny embedded nozzles blowing air over the surface of an airplane’s vertical tail fin showed future aircraft could be safely designed with smaller tails, thus reducing weight and drag. Also flown was a test of surface coatings designed to minimise drag caused by bug residue building up on the wing’s leading edge.
- A new process for stitching together large sections of lightweight composite materials that could be used in uniquely-shaped future aircraft that weighed up to 20% less than a similar all-metal aircraft.
- A radical new morphing wing technology that allows an aircraft to seamlessly extend its flaps, leaving no drag-inducing, noise-enhancing gaps for air to flow through. FlexSys and Aviation Partners of Seattle have already announced plans to commercialise this technology.
- In conjunction with GE, refining the design of the compressor stage of a turbine engine to improve its aerodynamic efficiency that could save 2.5% in fuel burn.
- Working with Pratt & Whitney on the company’s geared turbofan jet engine to mature and advanced fan design to improve propulsion efficiency and reduce noise. NASA says if introduced in the next-generation engine, the technology could cut fuel burn by 15% and significantly reduce noise.
- Also working with Pratt & Whitney on an improved design for a jet engine combustor to reduce the amount of NOx produced. Tests showed reductions of up to 80% could be achieved, beating the 75% goal.
- Developing new design tools to aid engineers in reducing noise from deployed wing flaps and landing gear during take-offs and landings.
“If these technologies start finding their way into the airline fleet, our computer models show the economic impact could amount to $255 billion in operational savings between 2025 and 2050,” reported Jaiwon Shin, NASA’s Associate Administrator for aeronautics research.
Significant studies were also performed on a hybrid wing body (HWB) concept in which the wings join the fuselage in a continuous, seamless line and the jet engines are mounted on top of the airplane in the rear. Many believe the conventional tube and wing shape that has predominated aircraft design has begun to reach its maximum ceiling on efficiency. The NASA research under ERA included wind-tunnel runs to test how well the HWB aircraft would operate at low speeds and to find the optimal engine placement, while also minimising fuel burn and reducing noise. The tests showed that against a target 1999 airplane, up to a 48% improvement in fuel burn and a 42dB cumulative noise reduction could be achieved, said Kevin James, NASA Ames ERA Program Manager.
“What that means for people living around airports is a significant improvement on aircraft noise to what they have come to expect,” he added.
NASA says research will continue on the HWB.
ERA Project Manager Fayette Collier described the project, which started in 2009, as challenging. “We had a fixed window, a fixed budget and all eight demonstrations needed to finish at the same time,” he said. “We then had to synthesise all the results and complete our analysis so we could tell the world what the impact would be.”
Ed Waggoner, Director of NASA’s Integrated Systems Research Program, added the project had delivered on all its goals. “It has been an unmitigated success,” he said. “Every one of our industry partners is getting something out of it.”
Information and results regarding each of the technology demonstrations have been categorised and stored for future access and use by the aerospace industry, and were due to be discussed at the American Institute of Aeronautics and Astronautics SciTech Conference in San Diego this week.
NASA ERA Project
Ambitions to supply all Sea-Tac flights with biofuel progress as airport launches study with Boeing and Alaska
Tue 5 Jan 2016 – The Port of Seattle, the governing authority of Seattle-Tacoma International Airport (Sea Tac), is partnering with Boeing and Alaska Airlines on a $250,000 feasibility study that will assess costs and infrastructure necessary to deliver aviation biofuel blends to airlines serving the airport. Under long-term roadmap plans, the ambition is for all flights departing Sea-Tac, which currently handles more than 380,000 flights annually, to be powered by sustainable aviation biofuel. The Port has a goal of reducing aircraft-related carbon emissions by 25% by 2037. A key strategy to achieving this is through such fuels and it has been involved in a number of regional research initiatives and the development of a market-support role. Alaska’s interest in the use of sustainable fuels goes back five years and was the first US airline to fly multiple flights using a blended biofuel.
An RFP for the infrastructure study will be issued in the spring and it is expected to be completed by the end of the year. As part of the biofuel roadmapping process, the Port will manage the study and would handle the the engineering and integration of the biofuel infrastructure on Port property, such as the airport’s fuel farm.
The Port of Seattle Commissioner, John Creighton, said the partnership with Boeing and Alaska on the study would signal to airlines and biofuel producers that the airport was ready to integrate commercial-scale use of aviation biofuels.
“Biofuel infrastructure will make Sea-Tac Airport an attractive option for any airline committing to use biofuel, and will assist in attracting biofuel producers to the region as part of a longer-term market development strategy,” he said.
As Sea-Tac points out, aviation biofuels are not yet produced in Washington state and must be imported by truck, rail or barge. The flights made by Alaska in 2011 were powered by 20% blends made from used cooking oil and waste animal fat (see article). However, the airline says within the next year it expects to fly the first-ever commercial flight on alcohol-to-jet fuel produced by Gevo, which is currently undergoing certification by ASTM (see article). In addition, as a partner in the Washington State University-led Northwest Advanced Renewables Alliance (NARA), it plans to fly a demonstration flight this year using a new aviation biofuel made from forest industry waste.
Joe Sprague, Alaska’s SVP Communications & External Relations, said the airline wants to incorporate biofuel into flight operations at one or more of its hubs by 2020, with Sea-Tac as its first choice.
“Biofuel offers the greatest way to further reduce our emissions,” he said. “This study is a critical step in advancing our environmental goals and stimulating aviation biofuel production in the Pacific Northwest.”
Added Boeing VP Strategy Sheila Remes: “Boeing, Washington state’s largest employer, is proud to work with our customer Alaska Airlines and the Port of Seattle to power every plane at Sea-Tac with a biofuel blend and lead the way for other airports to do the same.”
Port of Seattle - Environmental
Alaska Airlines - Sustainability
Boeing - Environment
COMMENTARY: Mitigation of international aviation emissions: The flightpath from Paris to Montreal
Tue 12 Jan 2016 – The COP21 climate summit last month produced a remarkable global consensus on the mitigation of anthropogenic greenhouse gas emissions and adaptation to their residual impact. Specific text addressing international aviation and shipping emissions was cut from the Paris Agreement during the meeting – seemingly with cursory consultation at most – and proved too difficult to reintroduce in the pressures of the final hours. But the Agreement embodies several features, notably increased ambition, which will serve to guide continuing work on mitigation of aviation emissions through ICAO. Of particular relevance is the development by ICAO of a global market-based measure (MBM) for consideration by the 39th Session of its Assembly later this year and intended implementation from 2020. Chris Lyle reviews some implications of the Paris Agreement for ICAO’s undertaking.
In its biannual report to the UNFCCC’s Subsidiary Body on Scientific and Technical Advice (SBSTA), which convened during COP21, ICAO noted it had formulated a ‘basket of measures’ to reduce emissions from international aviation, including air traffic management modernisation, acceleration of the use of fuel-efficient aircraft technologies, and the development and deployment of sustainable alternative fuels for aviation. Significant efforts were ongoing to fulfil the request of the 38th Assembly in 2013 for the Organization to develop a global MBM scheme for international aviation. The coming Assembly Session will consider a recommendation on the scheme that addresses key design elements and the implementation mechanisms from 2020.
Technological and operational improvements have produced significant achievements in aviation fuel efficiency over the past decades. A global CO2 certification standard is due to be adopted this year – although this will very likely be based on existing technology, apply only to new aircraft and exclude new versions of existing aircraft. Substantial progress has also been made on the use of sustainable alternative fuels, but their availability and price, along with full life-cycle assessment of biofuels, limits the prospect of their extensive contribution to aviation emissions mitigation at least until the long term. Overall, air traffic growth continues to outstrip appreciably the per unit reductions in emissions. The ICAO MBM scheme will therefore be crucial if international aviation is to play a requisite part in global emissions mitigation.
There were four key aspects of COP21 that are of direct relevance for the ICAO process of mitigation of international aviation emissions: ambition, differentiation, financing and the constitutional arrangements.
Ambition: The negotiations in Paris markedly demonstrated increased emissions mitigation ambition by countries worldwide, notably to hold global warming well below 2°C and to pursue efforts to limit the temperature increase to 1.5°C above pre-industrial levels. This will require ratcheting up the Intended Nationally Determined Contributions (INDCs) submitted to the UNFCCC for COP21 by 187 countries, which the UNFCCC estimates would, if fully implemented, limit the temperature increase to 2.7°C. The first global review of this ratcheting up will be undertaken by the UNFCCC in 2018.
International aviation emissions are not part of INDCs but, unlike the vast majority of the INDCs, are predicted to show significantly continued growth to, and even beyond, 2030 rather than any peaking or reduction. The UNFCCC, using ICAO data, forecasts that by 2020, international aviation will emit 750 MT of CO2 emissions alone, that is 79% above the 419 MT in the 2005 base year and 21% above the current ICAO aspirational goal of 620 MT for 2020 (derived from ICAO forecast traffic growth and annual average fuel efficiency improvement of 2% from 2010).
For 2020 onwards, ICAO decided at its Assembly in 2010 to adopt an aspirational goal – taken from an earlier aviation industry target – of Carbon Neutral Growth (CNG2020). This was to be based on actual 2020 emissions rather than those predicted at the time. Absolute international aviation emissions are expected to increase by some 40% from 2020 through 2030 – and to continue to grow beyond that. Carbon neutrality would be achieved through an MBM, most likely some form of carbon offsetting.
On offsetting, it should be noted, UNFCCC Executive Secretary Christiana Figueres has pointed out that it “is not a silver bullet, nor an alternative to the deep and decisive emission reductions that economies and communities have to make now and into the future.”
When the concept of an MBM was initially proposed for international aviation, it was anticipated as being only a short to medium term measure, until technology and sustainable alternative fuels kicked in, not only to achieve CNG but indeed to move progressively below it. There is now realisation that the ‘wedge gap’ to be filled merely to achieve CNG will get larger and larger for the foreseeable future. The possible contribution of alternative fuels to fill the wedge gap is presently uncertain but optimistic estimates are for the MBM contribution in 2030 to be reduced by about 25%.
As highlighted in a recent study carried out for the European Parliament (see article) international aviation’s emissions of global CO2 are likely to rise substantially both absolutely and in terms of global share if the sector does not step up its commitment. Clearly, given the high ambition of the Paris Agreement, the goal of CNG2020 and associated offsetting needs to be revisited.
International aviation is sometimes considered a “special case” because of its catalytic effect. On two of the three pillars of sustainable development – economic and social – its contribution is on balance positive, which should weigh against its patently negative contribution to the third pillar, environmental. Thus reductions in international aviation emissions to the extent of the INDCs, especially when they are ratcheted up to reflect higher ambition, while desirable, may not be practicable.
But, as spelled out in the European Parliament study, international aviation and shipping “are industrial sectors similar to sectors such as electricity generation, steel or cement production. They are equally important to the global economy and to economic development as other economic sectors but not more or less important than, for example, electricity, chemicals or retail. Since all other sectors are likely to be extensively covered by the post-Paris global mitigation targets, international aviation and shipping need to be covered by similar requirements. Otherwise production abroad would be implicitly subsidised via local production through inappropriate low transport prices and thus again induce higher GHG emissions.”
That said, tourism is an economically important sector which is particularly effective in the transfer of wealth from rich to poor countries and more than half of international tourists arrive by air. In this respect, international aviation may be linked to several of the UN’s Sustainable Development Goals.
Financing: International aviation remains exempt from fuel taxes and earlier draft negotiating texts for COP21 had seen a levy on international aviation as a source of financing for the UNFCCC Adaptation Fund. Lobbying by ICAO and the aviation industry had the relevant text removed. But offsetting can be considered as a form of financing and, despite her reservations, Christiana Figueres has noted that “offsetting has a part to play and in doing so can generate some of the funding needed for clean energy and adaptation projects in developing countries.”
Differentiation: The Paris Agreement clearly reaffirms the principle of common but differentiated responsibilities and respective capabilities (CBDR&RC), in the light of different national circumstances. This is critical for the ICAO process, which has been struggling with the issue for many years. COP21 faced considerable difficulties in achieving an acceptable balance between relative national economic strengths and national GHG emissions, past and present. Dealing with aviation in isolation adds a third dimension: the standing of countries according to the level of international air transport traffic generated by their carriers, as well as the additional constituent of dealing with differing national circumstances at either end of a route.
Constitutional arrangements: Consequent upon the 1997 Kyoto Protocol, governments have been addressing international aviation emissions working through ICAO. The Paris Agreement renders large parts of the Protocol moot, at least after 2020. The UNFCCC is still well short of necessary ratifications regarding the second commitment period (2012-2020) and some additional countries are already considering withdrawal from the Protocol. So while the Protocol may continue de jure, in practice it has been relegated to history.
ICAO’s involvement with climate change issues actually predates the Kyoto Protocol. In 1996, at ICAO’s request, the Intergovernmental Panel on Climate Change agreed to undertake a special report on Aviation and the Global Atmosphere, which was published in 1999 and formed a basis for the Organization’s work on the subject. The report, incidentally, is currently being considered for updating. Therefore ICAO expects – and is expected – to proceed under its own mandate, with continuing reports to SBSTA, although this does not preclude modification as well as clarification of the process for dealing with international aviation emissions when the UNFCCC develops mechanisms for implementation of the Paris Agreement.
There are two fundamental governance differences between the Paris Agreement and ICAO. First, a major change between the failed climate negotiations in Copenhagen in 2009 and the success in Paris was that the process moved from ‘top down’ globally to ‘bottom up’ by individual States. ICAO, a global standard-setting body, has no precedent for a bottom-up process. Second, the actual commitments (INDCs) under the Paris Agreement are voluntary, a concept which is difficult to conceive for an air route with different Parties at either end – indeed ICAO’s initial consideration of offsetting has been that it should be mandatory.
One elemental weakness of the continuing treatment of international aviation emissions through ICAO is that there is no directly identifiable national commitment – only a global ‘sector determined’ contribution – and so the contribution of international aviation emissions does not have a high profile nationally. Not only is potential action diluted, international aviation is treated in a silo and not in the context of differing national circumstances and the relative contribution of aviation to the economy – notably for cases where tourism is critical. And, while membership of the UNFCCC and ICAO is essentially the same, the UNFCCC’s mandate is to reduce greenhouse gas concentrations in the atmosphere, while the primary focus of ICAO is to protect and promote international aviation.
ICAO’s MBM programme
Carbon pricing is widely recognised as a market-based measure which is both simple and effective, moving industry and consumers to greener fuel sources. But in the case of aviation there is no effective alternative to the widespread use of fossil-based fuel for the foreseeable future and carbon pricing has been shown to have a minimal effect on traffic and hence emissions. Thus the ICAO Council initially considered three other MBMs: emissions trading, carbon offsets with revenue generation and carbon offsets without revenue generation, but it has focused only on the latter. Emissions trading can be more effective than offsetting and there is already experience of it for air travel within Europe but it is more complex. Both emissions trading and offsetting incur significant management costs and inefficiencies.
Since 2014, an Environment Advisory Group (EAG), comprising 17 of ICAO’s 36 Council Representatives, has been discussing a global MBM on the basis of a ‘Strawman’ prepared by the ICAO Secretariat and covering CO2 emissions only. This distributes offsetting obligations to operators based on a mix of collective and individual share of emissions growth. Credits would be generated outside the international aviation sector to avoid double counting of emissions. Widely differing national and regional positions have led to the introduction of possible amendments, for example:
- Adjustments to give preferential treatment to ‘early movers’ (prior to 2020), ‘new entrants’, and ‘fast growers’ – the latter two seem to be in direct contradiction of emissions mitigation.
- Exemptions for routes to and from States that fall below a de minimis threshold of emissions generated by all international flights to and from the State.
- Differentiation of offset obligations by route.
- Phase-in of routes, i.e. temporary exemptions.
While the reports of the EAG are not public, some insight as to current alternatives proposed in pursuance of broader application of CBDR&RC may be seen in submissions to SBSTA last month (see article) and related releases during COP21:
- ‘Accumulative’ historical emissions – operators offsetting obligations to be based on historical emissions (going back to 1992).
- States, rather than operators, to be the ‘accountable entities’ of the scheme.
- A fixed levy on international flights.
This author has long propounded the route differentiation concept to bridge CBDR&RC and the equal application provisions of the Chicago Convention, but has based this on generic national circumstances rather than international aviation traffic. Exemptions or reductions for routes to and from least developed, small island and landlocked developing States is a concept which catches the tourism concern mentioned previously, is rational in terms of the importance of aviation to the economies concerned, and has pre-existing classification in the UN, with the latter two categories of States specifically identified in the Paris Agreement.
If the MBM scheme includes significant exemptions/phase-ins/reductions for certain routes or carriers then this could of course affect the worldwide goal of CNG2020. The EAG defines CNG as applying to emissions from international aviation “that are not otherwise exempted”, which could diminish the goal. The only logical alternative would be that the MBM contribution be higher for non-exempted routes and carriers to compensate for the exemptions but this would probably be politically unacceptable.
The ICAO Council has tasked its Committee on Aviation Environmental Protection (CAEP) with analytical work and technical support on such issues as assessing the emissions from various alternative fuels, Monitoring, Reporting and Verification (on which the UNFCCC has itself yet to develop a generic mechanism), and Emissions Unit Criteria (deciding which offsets should be eligible in the global MBM).
Clearly there are many questions outstanding. One particular concern remains how effective the offsetting would be. The UNFCCC, which originally established specific carbon market mechanisms pursuant to the Kyoto Protocol, is now actively promoting them, notably through the Clean Development Mechanism. There are also a number of national and subnational schemes, and many non-governmental, voluntary mechanisms. But some developing States are known to oppose the concept of offsetting. Also, in the current voluntary market, there are offsets of widely differing quality and prices. Some do meet a Gold Standard, and a recent analysis by Germany’s Oeko-Institut indicates that there would be a sufficient supply of quality carbon offsets to meet demand under a global MBM for international aviation (see article).
The MBM schedule
All these concerns have to addressed in the context of an extremely tight schedule. ICAO’s EAG is due to meet again briefly in January and February, with the major triennial CAEP meeting in between. These meetings will be followed by a second series of regional Global Aviation Dialogues (GLADs) in March/April and a High-level Meeting in May at which a draft Assembly Resolution is expected to be available for comment. A further draft is to be agreed by the Council in its session ending on 17 June, with the Assembly itself scheduled for 27 September to 7 October.
On the UNFCCC front, ICAO will present its biannual reports to SBSTA in June and during COP22 in Marrakech, 7-18 November.
One outcome of COP21 is that international aviation and shipping emissions are no longer under the radar but have become a mainstream concern. Should ICAO fail to reach a substantive agreement in October, the UNFCCC may consider more direct action on international aviation emissions. In addition, the EU may lift the suspension of application of its Emissions Trading System to intercontinental flights and there could develop a patchwork of regional and bilateral emissions regimes applying to international air transport.
The stakes are therefore high, but the difficulties of ICAO reaching a meaningful and robust agreement on a global MBM should not be underestimated. And, like the Paris Agreement itself, an ICAO Assembly Resolution (which is non-binding, but needs consensus) will remain a paper tiger until implementation elements are defined, acted upon and verified.
Chris Lyle, a former employee of British Airways and ICAO, is Chief Executive of Canadian-based Air Transport Economics. Over the past two decades he has been particularly engaged with the symbiosis between aviation and tourism, and their association with climate change. He can be reached at email@example.com.
A PDF version of this article can be downloaded here