The fight must go on to protect the EU's right to continue with its own aviation emissions scheme
Fri 28 Sept 2016 – Over the next couple of weeks, the United Nations’ International Civil Aviation Organization (ICAO) will be holding its 39th Assembly in Montreal. One of the key items up for discussion/agreement/stonewalling (take your pick!) is the development and implementation of a Global Market Based Measure (GMBM) to try and control and reduce civil aviation’s growing use of fossil fuel via the use of a price mechanism that includes the cost of CO2 emissions in airline ticket prices – the practical embodiment of the ‘polluter pays’ principle, writes Jeff Gazzard.
Why is this important? GreenAir Online readers, policymakers and those with an environmental responsibility across all sectors of the aviation industry, finally realise that the huge and continuing growth of flight kilometres, based on the consumption of ever-increasing volumes of tax-free kerosene as a fuel, produces a significant climate change impact.
All forecasts from every source that I have monitored in recent months confirm that aviation emissions will put global climate change targets, whether they be 2 degrees or the recent Paris UNFCCC agreement for a lower 1.5 degree limit, at risk. I am not going to look in any great detail at the figures as, frankly, they speak for themselves. At least the days of the industry’s strategy of “deny, delay and minimise” as a global corporate response to real and proven scientific, environmental NGO and enlightened policymaker concerns are taking a back seat. Hopefully, right at the back, cramped up against the rear bulkhead, by the toilets!
After years of campaigning, policy development, consultations, phoney PR wars and obstructive legal action, the European Union and its parliament voted in July 2008 to extend the EU Emissions Trading Scheme (EU ETS) to aviation. The vote was carried by 640 votes to 30. In my view it wouldn’t have been possible to have sent a stronger message to the entire aviation industry that the game was up!
With free allowances, complex MRV arrangements, reasonable quality carbon credit availability, all-outgoing flight coverage, new entrant capacity, significant penalties for non-compliance, permanent review and policy development/revision opportunities, open public access to performance reporting and with both Parliament and the European Commission’s (EC) Climate Action Directorate General willing to engage positively with all parties, the policy was a model framework. Not perfect, but capable of producing something workable and potentially toughened over time.
Of course, those paragons of accepting the will of the European Parliament – the global aviation industry – predictably went collectively nuts at this perceived threat to their very existence, mounting an even more aggressive campaign in what to date has proved an overall futile attempt to destroy the Aviation EU ETS.
Industry did however manage to get the scheme partially rolled back to cover intra-EU airspace emissions only by IATA developing and promoting its own parallel universe project, Carbon Neutral Growth from 2020 (CNG 2020). This claimed that a combination of measures – technology gains, increased load factors, better ATM and flight operations, plus the aviation alternative fuels/biofuels mirage – would just leave a small amount of CO2 emissions that could be mopped-up by voluntary purchases of low-quality (but cheap!) offsets.
Successful lobbying of civil aviation regulators and transport ministries globally achieved IATA’s goal – supported incidentally by all other aviation trade associations – of transforming their CNG 2020 outline into hard ICAO policy. This neatly puts control of targets, pricing, MRV and everything else, including, funnily enough, disbanding regional schemes (i.e. the Aviation EU ETS), firmly in the hands of what can only be described as an overly bureaucratic, slow, cumbersome and most importantly, entirely producer-captured body that dances (sadly and badly, rather like your Dad!), entirely to the aviation industry’s tune.
The EU’s olive branch offer to compromise on flight coverage, the so-called ‘Stop the Clock’ option, was and is conditional upon the ICAO GMBM project coming into force with a target outcome and components at least as effective as the Aviation EU ETS, plus with the bonus of global airline participation. Otherwise, what’s the point?
Let’s be clear: the entire industry despises the EU emissions scheme precisely because the free allowances will likely disappear over time, the cap will tighten and the unit cost of both carbon allowances within the scheme and their supply will likely rise and tighten too. The involvement of environment ministries means the industry’s symbiotic relationship with transport ministries and aviation regulators is also significantly watered down. The IATA/ICAO CNG project is simply a fig leaf of business-as-usual greenwash.
So where does this leave the EU scheme and the need for an environmentally effective response to aviation’s CO2 emissions? Here are my thoughts on the desired outcome from a European viewpoint:
Europe, in the form of a tough uncompromising alliance of the EU/EC, the four-person MEP ICAO Assembly delegation and European Member States, along with global environmental NGOs and those countries most at risk from climate change impacts, must come away with the EU’s right to keep the Aviation EU ETS intact.
By all means continue to work through ICAO on the GMBM but acknowledge this is not at all acceptable as it stands. Indeed, there really isn’t a complete, comprehensive policy on the table right now, more a fabulous wish-list.
Recognise that the “up to 80%” coverage figure quoted is not 80% of emissions but just future growth beyond a contrived baseline of a 2020 start and therefore unacceptably low. It also excludes approximately 40% of worldwide aviation emission as it doesn’t cover domestic emissions at all.
Current discussions of offset quality are simply not a serious policy outcome.
The degree of exemptions proposed are contrived and unacceptable.
The industry cannot be trusted to develop a 1.5 degree compliant policy and indeed most importantly for a UN body, ICAO cannot and should not sign up to a policy that fails to meet the Paris goal, as this proposal singularly doesn’t.
Two weeks from next Tuesday, when the Assembly starts, is a long time to expect anybody to hold their breath in anticipation that the Assembly will transform IATA’s ‘CNG from 2020’ project into a Paris 1.5 degree compliant policy to control and reduce civil aviation’s CO2 emissions. So I won’t be. But I do expect the EU to return from Montreal with the right to continue with its scheme – the fight will then go on.
Jeff Gazzard co-ordinates the European GreenSkies Alliance (GSA) network, which is involved in grass roots campaigning, policy development and international advocacy to control and reduce the negative environmental impacts of air transport. He was the co-rapporteur of a task force developing a set of environmental indicators for aviation within the 41-country intergovernmental European Civil Aviation Conference, with which GSA has Observer status. Jeff is an advisor to the WHO on transport, environment and health issues, and is also the policy advisor to the UK All-party Parliamentary Sustainable Aviation Group of MPs. Until recently, he was a Board Member of the Aviation Environment Federation.
