Europe’s primary weapon against global warming is the Emissions Trading Scheme (EU-ETS), a program rooted in the 1997 Kyoto Protocol. The EU-ETS encourages the use of climate-friendly technologies by rewarding businesses that invest in green technologies, thus turning their investments into quick, short-term profits.

Thus far, the aviation sector has not been required to do much to address climate change because international aviation is excluded from the Kyoto Protocol, which, through ICAO, merely urges countries to work at reducing aviation emissions.
Although ICAO has endorsed the idea of an emissions trading system to meet CO2 reduction objectives, prospects for a comprehensive global agreement appear distant.
Nevertheless, the organization plans this fall to formulate guidelines for contracting states that seek to implement such measures.

International air traffic in Europe has mushroomed in the last 15 years, raising aviation greenhouse gas emissions–which are directly related to the amount of fuel consumed–by 73 percent between 1990 and 2003. In July the European Parliament backed an idea from the European Commission to include aviation in its cap-and-trade program for CO2 emissions.

Since 1990, CO2 emissions from all aviation have increased by 87 percent and are now said to account for about 3.5 percent of the human activities that contribute to climate change. The Intergovernmental Panel on Climate Change (IPCC) has estimated that this share will grow to 5 percent by 2050, undermining the efforts of other industrial sectors to fulfill Europe’s Kyoto commitments.

After several years of study, the Commission decided that incorporating aviation into the EU’s greenhouse gas emissions trading system would be the most cost-effective way to reduce aviation’s impact on climate change.

Aviation and Emissions Trading
In an effort to tackle aviation’s small but growing contribution to climate change, in December the European Commission issued a legislative proposal that suggests imposing a cap on CO2 emissions for all airplanes arriving or departing from EU airports, while allowing airlines to buy and sell “pollution credits” on the EU “carbon market.” The target date for the aviation sector to start trading CO2 is 2011.

The proposal applies to all turbine-powered aircraft–including IFR helicopters–with an mtow of more than 12,566 pounds/5,700 kg. However, state aircraft and circular flights by test aircraft are exempted.

The Commission’s formal proposal to integrate aviation into EU-ETS will have to go through the legislative machinery of the EU institutions. Indeed, the proposal has to be adopted by the Parliament and EU member states in the Council of Ministers, a process that usually takes two or three years. In a first debate in February, environment ministers backed the Commission’s strategy, but divisions remained as to timing, ambition and geographical scope.

Although the air transport industry has made improvements to aircraft technology and efficiency, the resultant reductions in greenhouse gas emissions have not been sufficient to compensate for the 50-percent growth of global air traffic over the last decade.

The most contentious issue in the debate on ETS is whether to include international flights in the program. Non-EU airlines, especially those from the U.S., have made it clear that trade sanctions would likely follow the inclusion of international flights in the plan. The Commission plan maintains the idea of including international flights in the program, but proposes exempting them until 2012.

The other issue is how to determine the cap on emissions (EU or national), who to apply it to (airlines or member states) and how to distribute allowances.

The Commission proposed calculating the overall cap based on average aviation emissions in 2004 and 2006 and distributing allowances to airlines, not countries. It also suggested setting pollution limits EU-wide; giving airlines at least 90 percent of pollution permits for free in the beginning, with unlimited auctioning after 2013; and allowing airlines to trade emissions with other sectors already covered by the EU-ETS, rather than allocating aviation-sector-specific pollution permits that can be used (and therefore traded) only by the aviation sector.

Non-EU States Oppose Plan
The Commission’s plans to integrate aviation into the EU’s CO2 emissions cap-and-trade system received broad support from member states, but a majority of countries insisted that all routes–intra-EU and international–be covered by the program as of the same date.

This would effectively force foreign airlines to comply with EU aviation emissions rules. But U.S. carriers are adamant that this would be illegal and that the EU must wait for a global agreement to be reached by ICAO.

Senior officials in the Bush Administration have indicated that the U.S. would consider legal action to stop the EU from applying the plan to U.S.-based airlines.

FAA Administrator Marion Blakey reiterated U.S. opposition to EU plans to include airlines from non-EU countries in a proposed European emissions trading program, saying, “Many countries around the world, including the U.S., view this unilateral approach as unworkable and unsustainable under international law.” She added that the approach “is directly counter to everything ICAO stands for” and that “trying to impose a ‘one-size-fits-all’ solution on a complex issue in a global industry is a recipe for failure.”

There is great political sensitivity on the subject, said Guy Viselé, EBAA environment expert, and it is quite possible that the 27 European Union governments will not reach an agreement during the first round of discussions. This would lead to new deliberations, again consuming between 12 and 18 months.

At the ICAO CAEP panel, there was strong opposition to the idea of Europe imposing its ETS on international flights, not only from the U.S. but also from China, Japan, Brazil and India. The ICAO panel is developing guidelines for countries that want to adopt ETS for air transport, but voluntarily, as is always the case at the United Nations level.

The main problem lies with the geographical scope of ETS. To be implemented on all international flights, ETS would have to be negotiated on a country-by-country basis.

The EU could start to implement ETS alone in 2011 as it has planned. The EU already has some experience in this field with fixed facilities, but the aviation sector, with, for example, its changing fleet of aircraft, is more complex.

The European aviation lobbying sector (consisting of five airline associations, a business aviation group and an aircraft industry group) adopted a common position on ETS, saying it should ideally be global in scope, respect ICAO rules, be implemented initially on an intra-European basis and allow carriers a fair competition regardless of their nationality.

Achieving Sustainable Growth
Although EBAA agrees with the introduction of an Emissions Trading Scheme, it believes that business aviation in Europe contributes only a small amount of the CO2 emissions from the entire air transport industry, due to its young fleet and the efficiency of its low- or medium-thrust engines, efficient airframe aerodynamics, and much lower annual utilization than airliners.

Business aviation also flies direct routings, avoiding the unnecessary hub-and-spoke created by the airlines. EBAA prefers a system calculated on the basis of the effective emissions generated, with exclusion of the less polluting equipment, as is already the case for fixed locations. Installations producing less than 20 megawatts are excluded. The association maintains that such a system would prevent distortion of competition among business aircraft operators.

Since the adoption of the EC proposal in December, EBAA has been involved in various projects. In addition to joining the other European alphabet groups, it has carried out with Eurocontrol an analysis of the ecological impact of business aviation to determine the sector’s contribution to air transport sector CO2 emissions.

Based on the analysis of a full year (2005) of effective flights and on manufacturers’ estimated fuel consumption for more than 100 different types of business aircraft, this study shows that business aircraft operators make only a minor contribution to the CO2 emissions generated by the air transport sector as a whole. Analysis of flights departing from 25 EU nations shows that despite representing 6.36 percent of traffic, business aviation contributed only 0.88 percent of the CO2 emissions that come from the air transport segment. This contribution is reduced to 5.5 percent and 0.45 percent, respectively, when only intra-EU flights are considered.

Based on these findings, an exemption for aircraft with an mtow of less than 44,092 pounds (20 tonnes) or fewer than 20 passengers was considered in the draft EC proposal. That exemption was based on the Commission Impact Analysis, which identified 20 tonnes and 20 passengers as the best thres-hold. Unexpectedly, a last-minute change, bringing the minimum mtow to 12,566 pounds (5,700 kg) means that all turbine-powered aircraft from the King Air to the BBJ are now subject to the future European directive on ETS. Only the smallest business jets and VLJs would escape the rule.

“Such a reduced threshold would impose a disproportionate administrative burden on a large number of small and medium enterprises using business aircraft to support economic and social development in Europe, while having a negligible impact on aviation emissions,” said EBAA.

The key principle of the proposed EU Directive on ETS applied to air transport is that it should bring a real environmental benefit without inflicting a heavy, costly and complex administrative burden on the operators and authorities that execute and monitor the plan. The great majority of business aircraft operators have small fleets of one or two aircraft, flying a relatively low number of hours per year (less than 20 percent of their airline equivalent).

Monitoring several hundred or even thousands of operators for an insignificant environmental benefit would be counter-productive, said EBAA, which strongly supports the exemption of business aviation from ETS applied to air transport,
on the basis of minimal environmental benefits but a disproportionate, complex and impracticable administrative burden and economic cost for small operators.

EBAA and Eurocontrol are currently carrying out a new analysis that uses a modified Pagoda emissions estimation model using CFMU flight-plan statistics and a database that includes 120 different types of business aircraft, with consumption estimates done by the manufacturers as a reference.

For EBAA’s Viselé, however, it is clear that identifying each operator and each aircraft will be a heavy administrative burden for national administrations in relation to the expected benefits for the environment. According to the Eurocontrol study on business aviation released last year, there are 1,700 aircraft operators in Europe; 700 of them operate fewer than nine aircraft. There are about 150 IFR turbine helicopters in all of Europe.

If ETS is deemed too costly, the program might never take off.

The current plan targets only CO2 emissions, but the European Green Lobby wants its scope extended to other gas emissions such as nitrogen oxides (NOX).
Environmentalists also wanted to introduce a multiplier factor of 2.5 for aviation, arguing that a ton of CO2 lingers longer in the atmosphere than does other pollution on earth. This was rejected for lack of scientific evidence.

The European Federation for Transport and Environment (T&E) said the EC proposal was “too weak” and would lead to emission reductions of only 3 percent, less than one year’s growth of the aviation sector’s emissions. Jos Dings, director of T&E, added, “Not only does the industry stand to get double the permits of other sectors, the fuel tax exemption enjoyed by the sector is worth another E35 billion alone, not to mention the lack of VAT on tickets and the E20 billion European taxpayers have paid out in rescue aid to airlines.”

ETS is only the first step in a series of ongoing efforts to reduce international aviation’s contribution to climate change through different aircraft emissions (carbon dioxide and water vapor emissions, contrails and nitrogen oxides).

During the Kyoto debate on aviation, several other policy options were examined at the EU level, including a fuel tax–as kerosene is currently not taxed–but this would have required a unanimous decision in the Council of Ministers and was strongly opposed by the aviation industry.

More Changes Coming
Other polluting gases, including nitrogen oxides and the water vapor in aircraft condensation trails, could also contribute to global warming. The Intergovernmental Panel on Climate Change (IPCC) estimates that the total impact of aviation on climate change could be about two to four times higher than what stems from CO2 emissions alone.

According to the conclusions of the Stern report*, of the 24 percent of CO2 emitted by the transport sector, road transport accounts for 21 percent and air transport for 1.6 percent. “There are millions of cars out there for tens of thousands of aircraft. A car would be considered less polluting than aircraft on a given distance; your Suzuki SUV will not take you from Brussels to Moscow, while an aircraft will. We should compare apples with apples and not apply an economical ratio of tons per passenger per km,” said Viselé, who emphasizes that airplanes alone can fill some missions.

What is certain is that the ETS will remain on the EBAA agenda for the foreseeable future. Business aviation in Europe is taking climate change seriously and is planning to make its own contribution to the global effort to reduce CO2 emissions. EBAA is currently studying several methods to achieve this voluntarily and will make an announcement at this month’s EBACE in Geneva. There will be a special information session on Wednesday, May 23 at 2 p.m.

* Sir Nicholas Stern is a British economist and academic. He is the author of the Stern Review Report on the Economics of Climate Change, released on Oct. 30, 2006, in which he describes climate change as an “economic externality” and therefore addressing this externality should allow market forces to develop low-carbon technologies.�

U.S. Associations look for ‘green’ solutions

Among the subjects on the agenda at March’s NATA Airport and FBO Symposium were alternative fuels for turbine aircraft, a topic certain to attract more attention as environmental concerns come to the fore.

The Commercial Aviation Alternative Fuel Initiative (CAAFI) has made substantial progress in exploring alternatives to jet fuel, working with airline, manufacturer and airport representatives. CAAFI’s members, said Richard Altman, executive director, are working together to present a united front to fuel suppliers, which will ultimately have to be involved in manufacturing and distributing alternative fuels. Tests on some fuels have been conducted and approvals by engine manufacturers should occur soon.

While airlines and the military burn most of the jet fuel used in the U.S., Altman said that “it would be beneficial for general aviation to be involved. We’re happy to expand our group.” (Contact Altman at altrich@cox.net or [860] 721-8634). The Transportation Research Board of the National Academies was expected to release a request for proposals to explore airport cost/benefits for alternative fuels last month.
In the next two years, coal- and natural gas-derived isoparaffinic kerosene alternative fuel should be qualified, according to Altman, and this fuel will be a drop-in replacement for jet fuel and also usable for diesel-powered ground equipment.

NATA has spent a lot of time educating its members about environmental issues, and the session on environmental responsibility emphasized the need to prepare for problems before they happen. Walter Chartrand, general manager of AirBP’s general aviation division, said that too often, employees think about what to do only after a hazardous spill occurs.

To help improve spill response, he suggested, everyone who works for the airport or FBO and even contractors coming on site should be instructed on what to do in case of a spill. A good idea is placing contact phone numbers for environmental release emergencies on the back of airport workers’ badges.

The Environmental Protection Agency’s Troy Swackhammer updated attendees on the EPA’s spill prevention, control and countermeasure rules, which apply to airport fuel storage facilities and mobile refuelers. The initial plan to require some kind of containment basin for tanks or trucks “was a major issue for the aviation folks,” he said. “We heard you. You can’t have a dike following around a mobile refueler.”

Nevertheless, airports and FBOs must be ready for fuel spills, with active measures that “prevent a discharge to navigable waters of adjoining shorelines.” These could include drain systems that catch fuel and deployable containment equipment such as spill kits that can mop up fuel. If all else fails, Swackhammer explained, it remains incumbent on operators to have a contingency plan, a sample of which is available at www.epa.gov/oilspill.