As the European Union emissions trading scheme (EU ETS) expands to cover aircraft flying into and out of the EU starting in 2012, airlines based all around the world stand to feel the effects. Of course, U.S. regional airlines don’t fly into Europe, and until recently few of them spent much time considering the prospect of taxes on their carbon emissions. But as airlines face increasing public pressure to improve their environmental performance, the Regional Airline Association has responded with a campaign to educate its members about the potential implications of future regulation. 

“You’ve got an Administration that’s heavily focused on environmental impacts, period, regardless of whether it’s aircraft, automobiles…it doesn’t matter,” RAA senior director of regulatory affairs Liam Connolly told AIN. “Not one of my airlines had a very comprehensive understanding of what its risk was in this area. At this moment in time they at least need a snapshot of where they stand.”

An effort to take that “snapshot” took the form of a study for which seven RAA member airlines agreed to measure their energy use and environmental emissions with the help of a Web-based software program developed by London-based sustainability economics and risk-management company EQ2. The measurement process involved capturing actual data associated with energy use, greenhouse gases, water and waste. EQ2 then compiled a formal report for each of the airlines, summarized data gaps and reviewed the airline’s environmental performance.

“That was Part One,” said Connolly. “Part Two is just getting a sense of how we can move forward and, from my perspective, selfishly, it was so I could intelligently have conversations with people on the Hill. I can’t go in there and say, ‘We’re doing a great job’ when I don’t really know.” 

With some firm data in hand, Connolly can at least attempt to quantify how much pollution his member airlines do produce, as well as gauge the costs a given piece of legislation might incur. The study estimated that the seven airlines would have spent some $136 million in carbon taxes over a six-month period if, in fact, the U.S. were to adopt the EU ETS. 

“One of the things that absolutely stunned me was the dollar figure if we were to institute something similar to the European trading scheme,” said Connolly. “Right now it doesn’t look like they’re [going to do] quite that here in the U.S., but take that as the example and apply what you know and it’s kind of shocking.” Given that the seven airlines sampled represent only 52 percent of the RAA fleet, which itself accounts for just under half of the total U.S. domestic fleet, an exercise in extrapolation over a full year would yield a total figure Connolly called “just ridiculous.”  

Although Connolly expressed satisfaction with the results of the study, so-called data gaps compromised the integrity of some of the figures related to electricity and water use and waste generation, for example. Some airlines could produce utility information only from certain sites; others couldn’t contribute historical data for water and waste. 

“My environmental directors might be able to get a hold of fuel usage, which is an easy number to get,” said Connolly. “But when you call the CFO and ask how much we paid in electrical bills for our 36 locations across the country it becomes a little bit harder…you know, ‘do we count the downtown ticket counter in Washington, D.C. as a location?’ The amount of work that went into finding that started them on a head spin, which, frankly, is part of the reason I did it. I wanted them to realize that all of these things affect their total footprint, and that’s a risk.”

Of course, no one knows for certain how immediate that risk is, but Connolly noted that Congress “got really close last year” to adopting legislation. 

“As we push toward [election day in] November, and this being a controversial subject, I wouldn’t be surprised if it sat until after November,” said Connolly. “I know it’s a high priority on the Administration side.”  

The association’s environmental group, established roughly a year-and-a-half ago, meets regularly with engine and airframe manufacturers to exchange information about new technologies aimed at mitigating the risk to which Connolly refers. But convincing airline members to take the issue seriously enough to commit their own resources to tracking their environmental footprints might represent Connolly’s biggest challenge. None of the RAA members has committed to any program to do so.

“I see this as one of the single biggest cost centers that these airlines are going to be facing, possibly even bigger than fuel,” said Connolly, who added that he presented the results of the study to the RAA’s board of directors. “I think they get it, and I think they see it,” he said, when asked whether or not he sensed any urgency from the board members. “But when they look at their day-to-day operations, they see their bill for fuel, and they see their bill for electricity and they see all these things, but they don’t necessarily see them all as one big thing leading up to a piece of legislation.”