The Aircraft Emissions Debate in the U.S. and Abroad

June 27, 2008

As most people in business aviation know, business aircraft have a very small emissions footprint, and a record of continuous improvement in this area. Nevertheless, because in Washington the debate over environmental policy is largely about carbon emissions from all modes of transport, policymakers are considering the impact of aircraft emissions, including those used by the general aviation community.

The debate has been underway for some time in the European Union (EU), prompting U.S. legislators and regulators to consider whether the European approach might be used in the United States.

FAA Acting Administrator Bobby Sturgell recently stated: “I disagree with the Europeans’ view and their approach as well. But let me be clear – we ignore the European experience at our own peril.”

What Sturgell is referring to are the political and social pressures that launched an aviation emissions trading scheme (ETS) in Europe, set for implementation in 2012. The plan won’t be limited to the Europeans – all operators flying to and from the 27 European Union (EU) member countries must comply. Under the ETS, operators will be given a “cap” for how much carbon dioxide (CO2 ) and certain other emissions they can generate in one year. Though not yet finalized, officials are leaning toward providing 90 percent of the cap level free, at least initially, and auctioning the remaining 10 percent at market rates.

There’s much consternation in the international community regarding the EU’s unilateral action, which appears to violate the Chicago Convention that regulates international aviation. A special International Civil Aviation Organization (ICAO) committee has convened to resolve the impasse.

Where Is the Aircraft Emissions Debate Headed?

Here in the U.S., environmental groups and some members of Congress have been petitioning the Environmental Protection Agency (EPA) to begin regulating aviation emissions. Rep. Edward Markey (D-Mass), chairman of the House Select Committee on Energy Independence and Global Warming, in a January 8 letter to the EPA, noted that while aviation accounts for a small percentage of all emissions, its greenhouse gas growth is expected to triple by 2020. Markey asked the EPA to state its position on aviation emissions and global warming.

While the EPA considers its response, the aviation industry in the U.S. is reviewing what a European-style ETS might cost, and what the practice might mean for general aviation. Europe, to meet its commitment to the Kyoto Protocol agreed to in 1997, instituted an ETS in 2005 for power-generating plants producing more than 20 megawatts. The Kyoto agreement, signed by 175 parties, but not the U.S., calls for reducing CO2 emissions 8 percent from 1990 levels by 2012.

Currently, CO2 credits sell for between 15 and 30 euros per metric ton (2,205 lbs.) on the open trading market, according to Guy Viselé, the International Business Aviation Council representative to ICAO’s environmental arm. One ton of jet fuel produces slightly more than three tons of CO2 – the primary by-product of combustion and the largest contributor to greenhouse gas levels.

These costs could rise substantially. Given the scientific unknowns surrounding secondary emissions, like air-quality-impacting nitrous oxides (N2O), and ozone depletion phenomena like contrails, factions within the EU favor multiplying each operator’s CO2 emissions by a fixed amount, probably a factor of two.

Because in Washington the debate over environmental policy is largely about carbon emissions from all modes of transport, policymakers are considering the impact of aircraft emissions, including those used by general aviation.

Though final arrangements are not yet decided, Viselé says the free portion of CO2 caps will likely decrease to 80 percent by 2013 and progressively decrease to 0 percent by 2020, with revenue-funding initiatives to counter climate change.

What Emissions Trading Could Mean for Business Aviation

The impact on business aviation could be immense. A study by Ernst & Young predicted that the cost of emissions trading would be 60 times higher for business aviation operators than for airlines, in part due to the burden of administering the program, says Viselé. Although the sector accounts for 7 percent of European IFR flights, it emits less than 1 percent of the air transport CO2 emissions for flights into and out of Europe.

Potential alternatives that the European Business Aviation Association and others are pursuing for business aviation include carbon-offset programs, under which, for example, an operator could buy fuel that is supplied with offsets, or programs under which an operator could select its own off-set projects that meet established criteria. NetJets Europe is voluntarily participating in such an offset program, with mandatory participation by members. The company plans to have all of its customers “carbon neutral” by the end of 2012.

As presently conceived, the EU trading scheme would have an exemption for aircraft with gross weights less than 5.7 tons (roughly 12,500 lbs.). Whether such an exemption would stay in place is questionable. “Exemptions for business aviation are a hot potato,” says Viselé. “Even if well-justified on the basis of the small environmental impact and heavy administrative burden, it can be difficult to convince policymakers of the need to exempt business aircraft.”

SOME BASIC STEPS FOR MINIMIZING AIRCRAFT EMISSIONS:

• Start engines as late as possible
• On takeoff, retract flaps as quickly as possible
• Fly the most direct routes possible
• Use proper trim procedures
• Maximize the aircraft’s center of gravity
• Consider limiting use of air conditioning packs in high flow
• Reduce deadheads with supplemental lift
• Load only the fuel needed
• Consolidate missions
• Request the most efficient cruise altitudes for fuel burn from ATC