Dr Liu said the UN agency could play a central role in bringing states, manufacturers, airlines, airports and stakeholders together in the post-Covid transition towards a decarbonised future.

“A global policy under ICAO is crucial because this is the only way to ensure the success of this global transition that needs to take place, while leaving no country behind and avoiding distortion of competition,” she told the session, ‘Building a Path to Net-Zero Aviation’, moderated by LanzaTech CEO Jennifer Holmgren.

“The disruptions to the way of life of billions around the world will bring fundamental and widespread changes to who aviation serves, and how, once the pandemic is behind us. The aviation sector will need to rapidly adapt, to access green funding for investments in technology, operations and fuels, in order to meet the growing calls for a sustainable flying future.”

She said individuals too will play an increasingly important role in sustainability, choosing to fly with airlines and on aircraft with lower emissions.

Added the UK government’s Grant Shapps: “Absolutely fundamental to our ‘build back better’ plan is to decarbonise aviation, making planes cleaner and greener so the sector can grow in a sustainable and resilient way. It’s a process that started well before coronavirus but I consider it to be more important than ever that as we come out of it, we pursue it even more actively. Our single overriding goal is to make net-zero a possibility in aviation and to do so well before 2050.”

He said governments working alone could not tackle the issue and close collaboration with industry and also at a global level was needed, pointing to the setting up in the UK of the Jet Zero Council and the UK working through ICAO to set global net-zero, long-term goals and standards for aviation emissions.

“We want to use COP26 to help accelerate the transition to cleaner aviation,” he said. “We’re going to be working with the World Economic Forum (WEF) and other states to develop new policy tools that will help the deployment of SAF. For the summit itself, we’re seeking to arrange the provision of SAF for delegates’ flights at key UK airports and we’re going to encourage other countries across the world to do the same.

“The world is coming together around this policy discussion but only the power of government as a convener can bring it altogether and ‘grease the wheels’ to accelerate the process.”

Grazia Vittadini of Airbus said multilateralism and cross-industry unity was the common denominator in stimulating a sustainable and long-term recovery of the sector. “We clearly have the right level of ambition and science-driven targets,” she said. “Now we need to progress on the regulatory framework of policy support as well as robust and safe technology pathways to get us there.”

Schiphol’s Dick Benschop said that up until now there had been a scatter-gun approach to aviation sustainability policy that had been ineffective.

“We need to focus on three areas: carbon pricing schemes that encourage the right incentives, tackling the issue of SAF mandates and how to support R&D into new propulsion areas such as electric and hydrogen. Ticket taxes aren’t helpful as they add cost but don’t drive sustainability. Sustainability will have its costs but enormous benefits as well and we need policies that drive investments.”

He said there was cause for optimism, with policies taking shape in Europe such as the ReFuelEU Aviation initiative that he expected will introduce a SAF blending mandate. “This would be an enormous step forward,” he believes.

Other positive developments he saw included a coming together by the sector towards a commitment to net-zero aviation in 2050 in line with the Paris Agreement and the big oil companies making serious investment decisions on sustainable fuels.

Vittadini saw similar signs of optimism and said it was a false choice as to whether the aviation sector should first focus on recovering profitability post-Covid or remain committed to net-zero.

“At Airbus, we have accelerated our carbon-neutral ambition into a tangible plan to bring a zero-emission aircraft to market by 2035, which is the most direct contribution we can bring as a manufacturer,” she said.

“The pandemic has increased global understanding of how dependent we are on our environment. It’s become quite clear that any industry recovery and profit in the years to come will depend on ambitious climate protection plans in parallel.

“Another key implication for the industry, especially in Europe, is finding a balanced way forward for alternative fuel propulsion solutions and I see three priorities.”

First, she said, was the need to boost production and uptake of SAF through dedicated policy measures. “More specifically, I believe this policy should include prioritisation of sustainable fuels for aviation, investing in high-impact feedstock and conversion technologies, and cost-effective financing. SAF provides a short and long term solution to decarbonising the sector, while technology in parallel continues to evolve to achieve even more fuel-efficient aircraft than today.”

Another step would be to implement a “green stimulus” for airlines to enable them to retire old and less environmentally-friendly aircraft, she said.

“Replacing a single aircraft can save more than 4,500 tonnes of CO2 per year, with the saving rising to 37,000 tonnes if you consider long-range aircraft. Creating the right conditions, the right financing framework to allow airlines to modernise their fleet towards more fuel-efficient aircraft is a win-win and would help support the European green agenda.

“Lastly, we need to catalyse an industry collaboration like we have never seen before in recent history, joining forces with all stakeholders across the industry, the political arena and research institutions. It’s important to note that as with every new technology and innovation rollout, the global transition to zero-emission flight requires a total rethink of many elements of our intricate aviation ecosystem.

“Hydrogen will need a technical redesign of current aircraft. Engineers will need to take the technologies developed in automotive and space to bring the weight and the cost down, and making the technology safe and compatible with commercial aircraft operations. We’re going to need to mobilise changes to airport infrastructure and we’ve started working with several airports, including Schiphol, on the concept of an airport hydrogen hub. Of course, we’re going to need the cooperation of aviation authorities to certify future hydrogen-powered aircraft to airworthiness safety standards, not to mention government collaboration as a critical piece of the puzzle. We do welcome the R&D funding support we are receiving from the EU and countries including France, Germany, Spain and the UK.”

Established in 2019, the Clean Skies for Tomorrow (CST) coalition brings together around 80 aviation and fuel industry companies and other stakeholders, including international organisations and associations, think tanks, NGOs and academia, to facilitate the transition to net-zero flying by mid-century.

In their foreword to the ‘Sustainable Aviation Fuels as a Pathway to Net-Zero Aviation’ report, Christoph Wolff, Head, Shaping the Future of Mobility, at WEF and Daniel Riefer, Platform Fellow WEF and Associate Partner at McKinsey, said that with electric flight and hydrogen-powered propulsion still years away from application at scale, SAF is a necessary step in aviation’s decarbonisation pathway.

“The CST coalition is working to address the chicken-and-egg scenario whereby producers and consumers of SAF are both either unwilling or unable to carry the initial cost burden of investing in new technologies to reach a scale where they are more cost competitive with existing fossil fuel-derived options,” they write. “The aim is to break this impasse and advance the commercial scale of viable production of sustainable low-carbon aviation fuels (bio and synthetic) for broad adoption in the industry by 2030. This report, developed in close consultation with the CST coalition, serves to provide a fact base on which swift and bold actions should be taken by public and private sector leaders alike.”

In 2019, says the report, fewer than 200,000 tonnes of SAF were produced globally, amounting to less than 0.1% of the roughly 300 million tonnes of jet fuel used by commercial airlines. If all SAF projects that have been publicly announced are completed, capacity will scale to at least 4 million tonnes in the next few years, reaching volumes just over 1% of expected global jet fuel demand in 2030. However, it says, a transition to SAF is in reach and from a feedstock perspective, enough raw material is available to fuel all aviation by 2030.

To scale production and make SAF economically viable and scale production, the authors say several advances will be required: technological challenges must be overcome; a supportive regulatory framework needs to be installed to stimulate demand from corporate and private customers; and innovative solutions to finance the transition have to be implemented. “The CST coalition is debating how to meet these challenges and help aviation earn its right to keep growing,” says the report.

It concludes: “Producing sustainable aviation fuel will almost certainly continue to be more expensive than refining fossil jet fuel but the costs of exceeding the 1.5 or 2.0-degree targets of the Paris Agreement are incalculably greater.”

Top photo and video: World Economic Forum

Commenting on the outcome of the session, Council President Salvatore Sciacchitano said: “ICAO set out a vision for carbon-neutral growth in international aviation and we have now seen that vision bear fruit. The Council’s decisions on eligible emissions units and sustainability certification schemes are the final steps necessary for CORSIA’s timely implementation.”

The approval of EEUs applies for use with offsetting requirements in the pilot phase and are subject to their respective scope of eligibility and eligibility dates. Issued units must be in respect of activities that started their first crediting period from 1 January 2016 and in respect of emissions reductions through 31 December 2020. It requires TAB recommendation and Council approval for an extension to the eligibility timeframes beyond the pilot phase.

TAB has now recommended and the Council approved seven emissions units programmes for eligibility across the two assessment cycles: American Carbon Registry (ACR), Architecture for REDD+ Transactions (ART), China GHG Voluntary Emission Reduction Program, the UN’s Clean Development Mechanism (CDM), Climate Action Reserve (CAR), Gold Standard and Verified Carbon Standard (Verra).

The approval by ICAO of Winrock’s ART and Verra’s Jurisdictional Nested REDD+ (JNR) represents the first acceptance of REDD+ (Reducing Emissions from Deforestation and forest Degradation) standards in a compliance market and is an important moment in the development of REDD+, said the International Emissions Trading Association (IETA).

A paper published by IETA calls for increased investment to prevent deforestation and for carbon markets to channel finance to all pathways that protect, restore and enhance the ecosystems that draw down and store carbon from the atmosphere.

“We need to scale up finance to avoid deforestation – especially tropical deforestation – in a way that contributes to sustainable development goals in forested regions,” said IETA CEO Dirk Forrister.

The paper points out that many countries have included REDD+ activities as part of their Nationally Determined Contributions (NDCs) to the Paris Agreement and that scenario modelling indicates dramatic reductions in deforestation are necessary to help achieve the Paris Agreement’s 1.5C temperature goal.

“Reducing deforestation and the conversion of natural habitats must be prioritised and recognised for its significant climate change mitigation potential in the short-to-medium term,” said Ellen Lourie, Senior Policy Associate at IETA. “If forests are allowed to be destroyed, it won’t be possible to recapture and store the lost carbon in new forests quickly enough to meet the Paris goals.”

Natural Climate Solutions (NCS) is becoming an increasingly large component of the voluntary market, says IETA, and in 2019 forestry and land use represented over 50% of the market by value. The private sector-led Taskforce on Scaling Voluntary Carbon Markets is looking to increase the voluntary market by at least 15-fold by 2030, which, says IETA, represents an opportunity to direct significant new finance into forest protection.

Commenting on the ICAO outcome, Frances Seymour, Chair of the ART board, said: “We applaud the ICAO Council’s decision to approve jurisdictional REDD+ credits from ART. Protecting and restoring tropical forests can contribute up to one-third of the climate results the world needs over the next two decades, representing a massive mitigation opportunity that needs access to private sector capital at scale. ART was designed as a Paris Agreement-aligned, fit-for-purpose crediting programme that provides the assurance of integrity and safeguards that markets need.”

ART, which uses The REDD+ Environmental Excellency Standard (TREES), said its crediting ensures that jurisdictions meet standard market requirements for robust accounting, independent third-party verification and issuance of serialised units on a transparent registry. Despite the impact of the Covid pandemic and the subsequent adjustment to the CORSIA baseline that would delay the need for the airline industry to purchase offsets for compliance with the scheme, the ICAO approval had been interpreted as a ‘seal of quality’ by market participants, said ART. It stated that since the first crediting programmes were approved in March 2020, interest in purchasing CORSIA-eligible credits was increasing from outside the airline industry as a way to ensure they were investing in credible emission reductions.

“ART was established in anticipation of catalytic private sector interest in REDD+, especially in industries with hard-to-abate emissions,” said Mary Grady, Director of the ART Secretariat. “We hope ICAO’s approval provides the needed quality imprimatur for voluntary investments in REDD+ that extends beyond the global aviation sector.”

Mario Boccucci, Head of the UN-REDD Programme Secretariat, commended ICAO’s approval of jurisdictional and national REDD+ crediting programmes, adding: “The UN-REDD Programme is ready to continue to support REDD countries ensure high-quality and environmental integrity, and provide technical assistance to meet NDCs and raise ambition.”

NGO Environmental Defense Fund (EDF) has helped to establish the Emergent Forest Finance Accelerator, a non-profit finance intermediary supported by the Rockefeller Foundation and the Norwegian government’s International Climate and Forest Initiative, to facilitate large-scale REDD+ transactions using the ART framework. It is collaborating with ART, Emergent, the UN REDD Programme and Forest Trends on the ‘Green Gigaton Challenge: Bringing REDD+ to Scale’ that seeks to set a demand signal that can scale up to at least a billion tons per year in emissions reductions transacted from high-integrity jurisdictional REDD+ by 2025.

“ICAO’s decision connects limits on aviation carbon pollution with investments in tropical forest protection and restoration, and is a win for nature, countries, companies and communities,” said Ruben Lubowski, Associate VP for Climate and Forests and Chief Natural Resource Economist at EDF. “After more than a decade of work on REDD+ frameworks under the UNFCCC and other fora, this marks the first time that REDD+ credits have been approved for use within a global compliance carbon market system.

“ICAO’s decision to include large, jurisdictional-scale REDD+ programmes in CORSIA sends a critical signal to companies and policymakers about the value of tropical forest protection to meet climate goals. It shows forest countries that there is a tangible demand for emissions reductions of the highest environmental and social integrity. Approval of these programmes will drive progress in reducing emissions at the scale needed to achieve the climate goals set by the aviation industry and in the Paris Agreement.”

The focus of the TAB and ICAO Council on ensuring programmes obtain from host countries written attestations that they will properly account for the transferred reductions should add to the efforts of Parties in ongoing climate talks to finalise clear guidance to ensure environmental integrity and prevent double-counting of emission reductions, said EDF. The NGO has produced analysis to show global climate cooperation through carbon markets can enable double the emissions reductions under current Paris pledges for the same cost as countries acting alone.

At its November meeting, the ICAO Council also approved two Sustainability Certification Schemes, the Roundtable on Sustainable Biomaterials (RSB) and the International Sustainability and Carbon Certification (ISCC), as eligible to certify CORSIA Eligible Fuels, based on recommendations by ICAO’s Committee on Aviation Environmental Protection (CAEP). The use of such fuels enables aeroplane operators to reduce their CORSIA offsetting requirements from the use of low-carbon and sustainable aviation fuels (SAF) that must be certified by one of the two organisations, although there is a degree of mutual recognition between them. Such fuels must meet the CORSIA Sustainability Criteria, including to achieve net GHG emission reductions of at least 10% compared to the baseline lifecycle emission values for conventional aviation fuel and not be made from biomass obtained from land with high carbon stock.

RSB has developed its own CORSIA Standard which it said goes above and beyond the ICAO scheme’s requirements to ensure that SAF achieves at least 50% GHG reductions on its core lifecycle analysis and a minimum 10% when including CORSIA’s Induced Land Use Change values (ILUC). In addition, it adds, RSB-certified SAF enables further claims around zero deforestation, environmental protection, food security and human rights, as specified in the RSB Principles and Criteria.

RSB is supported and endorsed by many in the aviation industry and also by environmental NGO coalition group ICSA. Airline members of the Sustainable Aviation Fuel Users Group (SAFUG), representing around a third of global commercial aviation fuel consumption, have committed to developing and using fuels consistent with RSB’s sustainability requirements. A third of RSB’s members are from the aviation sector. RSB certificate holders include Gevo, Nuseed, SkyNRG and World Energy, with further commitments to RSB certification from Velocys, LanzaTech and LanzaJet. KLM has committed to sourcing RSB-certified SAF.

Renewable jet producer Neste is also supporting RSB certification standards. “We cordially congratulate RSB for receiving ICAO recognition for its standard and we look forward to continuing the close collaboration,” said the Finnish company’s VP Business Development, Renewable Aviation, Sami Jauhiainen.

“A clear pathway is now available for industry leaders to demonstrate their commitment to sustainability goes above and beyond the legal requirements of CORSIA to also include a full range of social and environmental impacts as well,” commented Rolf Hogan, RSB’s Executive Director, on the ICAO approval. “We look forward to working with these pioneers to implement this new RSB CORSIA Standard to help transform the industry, and the world.”

Added Pedro Piris-Cabezas, Director of Sustainable International Transport and Lead Senior Economist at EDF: “ICAO Council’s approval of RSB is both an outstanding achievement for RSB and a major milestone for CORSIA, which completes CORSIA’s SAF framework. RSB’s CORSIA standard also represents a paradigm shift, moving from RSB’s original focus on sustainable biofuel volumes to a new focus on emissions reductions from the use of SAF for carbon markets.”

ISCC has also expanded the sustainability requirements for CORSIA eligible fuels with additional criteria that aims to protect water, soil, air, biodiversity and workers’ and land rights. “ISCC covers the complete set of CORSIA requirements, allowing economic operators at every point in a fuel’s supply chain to show their compliance with the CORSIA scheme by becoming ISCC CORSIA certified,” said the Germany-based certification body.

Commenting on the Council outcome on eligible units and sustainability certification schemes, ICAO Secretary General Dr Fang Liu said: “The steps that ICAO has taken to address climate change go hand-in-hand with our efforts to promote the sustainable growth and long-term prosperity of international aviation. CORSIA’s implementation elements are ready, and States and airlines are ready to make us of them.”

ICAO has launched a series of videos on ‘Navigating CORSIA’, which are guides to the scheme’s design and implementation.

The aircraft CO2 standards were adopted by the ICAO Council in March 2017 and are contained in Annex 16 of the Chicago Convention. It applies to new aircraft type designs from 2020 and to aircraft type designs already in production as of 2023. Those in-production aircraft which by 2028 do not meet the standards will no longer be able to be produced unless their designs are sufficiently modified. The EPA and FAA represented the United States on ICAO’s environmental protection committee CAEP, which drew up the standards.

After legal challenges by environmental groups, in 2016 the EPA issued findings that within the meaning of section 231 of the Clean Air Act, elevated concentrations of greenhouse gas (GHG) emissions in the atmosphere endangered the public health and welfare of current and future generations, and that GHG emissions from certain classes of engines used in certain aircraft are contributing to the air pollution that endangers public health and welfare.

As such, the EPA is proposing to regulate GHG emissions from covered airplanes through the adoption of domestic GHG regulations that match ICAO’s international CO2 standards. Covered airplanes are civil subsonic jet aircraft with a MTOM greater than 5,700 kgs and larger civil subsonic turboprop airplanes with a MTOM greater than 8,618 kgs. It proposes to adopt the ICAO CO2 metric, which measures fuel efficiency, for demonstrating compliance with the GHG emissions standards. The metric is a mathematical function that incorporates the specific air range (SAR) of an airplane/engine combination – a traditional measure of airplane cruise performance in units of km/kg of fuel – and the reference geometric factor (RGF), a measure of fuselage size.

To measure airplane fuel efficiency, the EPA is proposing to adopt the ICAO test procedures whereby the SAR value is measured in three specific operating test points, and a composite of those results used in the metric to determine compliance with the proposed GHG standards. In order to be consistent with the current annual reporting requirement for engine emissions, the EPA is also proposing to require the annual reporting of the number of airplanes produced, airplane characteristics and test parameters.

The EPA says US manufacturers have already developed or are developing technologies that will allow affected airplanes to comply with the ICAO standards, in advance of its adoption, and it anticipates nearly all affected airplanes to be compliant by the respective dates for new type designs and for in-production airplanes. This includes the expectation that existing in-production airplanes that are non-compliant will either be modified and re-certificated as compliant or will likely go out of production before the production compliance date of 1 January 2028.

“For these reasons, the EPA is not projecting emission reductions associated with these proposed GHG regulations,” it states in the executive summary of the proposed rule.

The EPA held a virtual public hearing on September 17, with participation from aircraft and engine manufacturers, aerospace and airline industry associations, environmental organisations and other interested parties. Over 120 written public comments have been submitted in response to the proposal by the October 19 closing date.

A coalition of environmental groups that first filed a suit against the EPA over a decade ago to force the agency to address GHG emissions from aircraft said the proposal violated section 231 of the Clean Air Act (CAA) as it failed to reduce GHG emissions from aircraft despite the EPA’s own endangerment findings.

“Moreover, the proposal’s failure to consider the statutory factors laid out in section 231, over-reliance on factors outside the statute, failure to analyse the costs and benefits of a sufficient range of possible emission standards, and refusal to select an alternative based on the evidence before the agency are arbitrary and capricious,” says the submission by Earthjustice, Center for Biological Diversity, Sierra Club, Friends of the Earth and Natural Resources Defense Council.

“These flaws cannot be remedied in a final rule. Instead, EPA must replace the proposal with one that meets its duties under the Clean Air Act. The final regulations must employ strong mechanisms to reduce emissions from aircraft and protect the public health and welfare and in doing so, EPA must consider the full panoply of available measures, including declining fleetwide emissions averages and operational and design improvements.

“To avoid catastrophic climate change, EPA must implement standards that far exceeds ICAO’s standards in both stringency and scope.”

The submission dismisses the EPA’s argument that US manufacturers would be at a competitive disadvantage if the US failed to adopt standards in line with ICAO’s. “EPA provides no legitimate basis for this assertion. Nothing prevents the US from adopting standards that are more stringent than ICAO’s and EPA has responsibility to do so if that is what public health and environmental protection require.”

Commenting on its own submission, Annie Petsonk, International Counsel for the Environmental Defense Fund, said: “As EPA’s own analysis indicates, the proposed standards will not drive emissions down. It simply embodies what the industry has already baked in. To justify its approach, EPA relied on a problematic estimate of the costs of doing nothing, arbitrarily ignoring the real costs of climate pollution that people across the country are facing every day.

“As the aviation industry tries to bounce back from Covid, it must put addressing the climate crisis at the core of its recovery, and government needs to lead the way. A stringent aircraft pollution standard would mean jobs building the aircraft and creating the fuels of the future. Instead, EPA’s proposed aircraft rule ignores the science and contravenes laws that require it to protect public health and the environment.

“We urge EPA to replace its proposal with standards that will actually reduce aircraft emissions, as one key element of a broader package of carrots and sticks to get the aviation industry to take real steps to cut climate pollution.”

In its submission to the EPA, the non-profit environmental research organisation International Council on Clean Transportation (ICCT) said its analysis showed new deliveries of commercial aircraft in 2019 were on average 6% more fuel efficient than required by the ICAO standards.

With some caveats, the industry response to the EPA’s proposal is supportive of legislation in line with ICAO CO2 standards, which it sees as meeting the criteria set out in the CAA’s section 231.

“Adopting the standards into US law will ensure US-manufactured aircraft and engines are available to US airlines, while fostering global competition and enabling our airlines to acquire aircraft and aircraft engines at market-driven, competitive prices,” says a joint submission by Airlines for America and the Air Lines Pilots Association International. “Especially given that, as the agency itself notes, other ICAO member states that certify airplanes have already adopted the ICAO CO2 standards, the agency needs to act to put US manufacturers on the same footing as their foreign counterparts.”

The two trade bodies said the ICAO standards would achieve GHG emissions reductions, support US policies to combat climate change and provide international uniformity. “Aircraft and the international airspace system simply could not function if aircraft and aircraft engines were subject to disparate regulatory requirements and standards.”

However, they asked the EPA to clarify in its rulemaking that the proposed US standards did not apply to in-service aircraft and disagreed with the agency’s conclusion that there could be no costs or benefits attributable to the standards.

A submission by the Aerospace Industries Association (AIA) said its members had already taken steps to ensure compliance with the proposed standards, including making plans to end production of the least fuel-efficient aircraft.

“The majority of aircraft will not be subject to the standards until 1 January 2028. Nevertheless, we urge the EPA to finalise the domestic adoption of these rules by the end of this year,” said the AIA. “Airlines purchase aircraft several years in advance. They are currently deciding on aircraft that will be delivered through the end of this decade. When making these decisions, airlines will require assurances that aircraft meet the standards to operate in international markets.

“Without domestic regulations in place, the FAA would be unable to certify an aircraft as meeting the ICAO CO2 standards. In this situation, US manufacturers would be at a serious competitive disadvantage if airlines were to seek greater regulatory certainty by opting to purchase aircraft manufactured elsewhere that meet the requirements of their certifying authority’s equivalent rules, which have already been implemented in some cases.

“If this was to occur, it could jeopardise tens of billions of dollars in sales for the US aerospace industry.”

Engine manufacturer GE said the proposed rule would provide the global aviation industry with much-needed certainty and consistency as it faced the Covid crisis and its adoption would satisfy US obligations under the Chicago Convention by ensuring compliance with ICAO standards.

GE also argued that more stringent GHG standards were not appropriate and would potentially violate the Clean Air Act.

“The CAA does not require the EPA to ‘technology force’ at the risk of flight safety,” said the submission. “[It] requires EPA to refrain from changing aircraft emission standards if such a change would adversely affect safety. To maintain the trust and confidence of the flying public, it is imperative that EPA not adopt standards that could in any way be perceived as sacrificing aviation safety. The perception of the flying public matters and EPA should endeavour to avoid any erosion of public confidence in the safety of aviation. This objective is best achieved by EPA remaining aligned with the ICAO analytical criteria of technical feasibility, environmental benefit, cost effectiveness and impacts of interdependencies, which have helped ensure the continuation of aviation’s impressive safety record.

“Moreover, when preparing this proposal, EPA carefully analysed the impacts of two more stringent alternatives. These analyses show that the alternatives would lead to minimal reduction in GHG emissions, while imposing significant costs associated with deviating from the ICAO standards. Consequently, EPA appropriately decided against proposing either of these alternatives.”

While supportive of aligning EPA regulations with the ICAO CO2 standard, both Boeing and Airbus are opposed to the reporting requirements laid out in the proposal. Boeing said they were unnecessary as they were duplicative of FAA reporting requirements, “and unwise because they pose unnecessary risks to Boeing’s confidential business information and potentially the nation’s security.”

The concerns are centred on fears the EPA could make public manufacturers’ specific air range data.

“SAR data is highly sensitive, treated by Boeing and other airplane manufacturers as a trade secret and protected zealously from disclosure to competitors and the public,” says the Boeing submission. “because of the strategic value of SAR data, it can also be subject to federal export controls and sanction regimes.

“There is also a risk that someone could wrongly argue that SAR data should be considered to be emissions data or ‘related technical information’ that EPA must disclose. EPA should not collect SAR data … and should not require reporting of that data. If it nonetheless requires reporting of SAR data then EPA must ensure that data is protected from public disclosure.

“EPA need not collect SAR data to track airplane CO2 emissions performance and verify compliance. ICAO agreed to the use and public reporting of an aircraft’s [fuel efficiency] metric value for this purpose because it is sufficient by itself to enable assessment of compliance with the CO2 emissions standard, while continuing to maintain the confidentiality of manufacturers’ SAR data. Significantly, ICAO does not require public reporting of RGF – an important element of SAR data – precisely because it can be used to derive an airplane’s SAR.”

Airbus too said SAR data and the reference geometric factor were highly commercially sensitive information. It also questioned the EPA’s authority to request such information when a large number of airplanes delivered around the world would never operate within the United States.

“ICAO is the right body to create international standards,” said the Airbus submission. “Airbus believes that in the absence of a worldwide harmonisation process, regional requirements could produce unintended consequences that would harm the aviation industry. We therefore urge the EPA to adopt the proposed ICAO rule with no additional requirements.”

The ICAO Aircraft CO2 standards are contained in Volume III to Annex 16 of the Chicago Convention and were adopted in Europe by the European Parliament and Council in July 2018 (Regulation (EU) No. 2018/1139). The European Union Aviation Safety Agency (EASA) published certification specifications concerning the standard in August 2019.

Photo: Boeing