Public comments on the ICAO aviation offsetting scheme

Here is the cover letter for my public comment on the International Civil Aviation Organization (ICAO) offsetting scheme, called CORSIA. The UN agency has received 14 proposals for offsetting programs, and seeks public comment on whether they satisfy evaluation criteria. Perhaps the most difficult criterion, which the proposals I read do not meet, is the additionality criterion. I first heard about the open comment period yesterday.

Dear ICAO:

Here attached are my public comments on the first 5 of the 14 offset proposals (ordered alphabetically). Insufficient time was provided in the public comment period for me to read the remaining proposals.

The due date for comments is Sep. 5, and the first notice I can find announcing the open comment period, anywhere on the internet, is Sep 3. Because the ICAO website does not give an opening date for the comment period, and the ICAO Twitter feed does not contain any announcement of the comment period, I can find no evidence that this comment period was longer than 2 days. Clearly, this is not proper procedure.

Overall, the approach to additionality is not credible. Every sector of society is rapidly paying more attention to the climate crisis. Across the board, the baselines used in these proposals take insufficient account of future actions by external actors (outside of the offset scheme) that will simultaneously be seeking to affect emissions.

To give just one example, suppose an offset program funds fuel-efficient wood stoves to replace open cooking fires in a low-income country. The proposed “additionality” certification states that, in the absence of the offset program, households would continue to cook on open fires. The full emissions reduction from the change to new stoves is credited to the offset program as “additional.” But this is not plausible. In a time of climate crisis, countries around the world are rapidly expanding electrification, and the electric grid in turn is relying more on renewables. Rural people in low-income countries are moving by the millions to cities, where they are more likely to have electricity. To assume the households would all continue using cooking fires is not plausible. So the offset scheme gets credit for far more emissions reduction than was in fact achieved.

This problem is pervasive in the proposals I read today.

Here are my comments in the format of your official rubric, on just 5 proposals, but but my public comment greatly understates the deep emptiness of this offsets approach.

What really is needed from ICAO and CORSIA is actual emissions reductions within the aviation sector. It is a travesty that ICAO only provides overall goals for emissions “net” of offsets, and will not state goals for actual emissions reduction in the aviation sector.


Parke Wilde

Among the 14 proposals, the Clean Development Mechanism (CDM) sent what appears to be a cover letter. I could not find any proposal in the required format. The cover letter did not mention the additionality criterion, as far as I could tell. The CDM’s ability to deliver additionality has been criticized in the past: How Additional is the Clean Development Mechanism?

Aviation “exceptionalism” in the NY Review of Books

In the New York Review of Books yesterday, Rebecca Tuhus-Dubrow puts her finger on what is so distinctive about aviation in a time of climate change:

Aviation has long enjoyed a kind of exceptionalism. Many people who take pride in their green lifestyles—perhaps they bike to work and always carry a travel mug—also happen to be frequent flyers. This incongruity grows in part out of cultural factors. A certain type (and I count myself in this category) aspires to be both worldly and socially conscious. We would never think of driving an SUV, say, but we’ve been known to drop the names of far-flung capitals we’ve visited. To be sure, our portable bamboo utensil sets and canvas grocery bags accord with our principles, but they also accord with our self-image, our aesthetics, our personal brands.

The article covers our university-centered petition, which now has 670 academic supporters. See also Twitter handle @flyingless and FAQ.

Parke Wilde, a food economist at Tufts University, and Joseph Nevins, a geographer at Vassar, established a petition, asking universities to take measures to reduce flying by faculty, staff, and students “commensurate with the cuts suggested by climate science.” …

To some environmentalists, particularly in the UK, there was a simpler, albeit not especially appealing, answer: If you want to prevent the damage caused by flying, you shouldn’t fly. Beyond Flying, an anthology that appeared in 2014, included essays mainly from British writers and activists, all of whom had changed their flying behavior as a result of climate concerns.

That book was pivotal for Parke Wilde, the Tufts food economist. Starting about a dozen years ago, he had begun to consciously reduce the number of flights he took. Then, inspired by the anthology and a couple of other non-flying academics—Kevin Anderson, a climate scientist in the UK, and Nevins, the Vassar geographer—he decided in 2014 to stop flying altogether. Wilde and Nevins run a blog titled Flying Less.

Non-flying academics can’t help but notice a conspicuous tension between, on the one hand, the espoused values of universities and professors, and, on the other, the flying behavior that is condoned, incentivized, and relished at their institutions. Professors are not especially highly paid, considering their educational credentials, and getting flown out to give talks and hobnob at conferences in destinations such as Berlin, Bangkok, or Johannesburg is a major perk of the job. At the same time, even if they would prefer to stay put, junior faculty members feel pressure to travel, in order to schmooze with colleagues and promote their work.

With their petition, which currently has signatures from more than 600 academics, Wilde and Nevins ask both universities and professional associations to take steps to modify this system. One idea they propose is the “regional hub” conference model, in which academics would congregate in their respective regions for personal connections and use video-conferencing to interact with other hubs. A few of these associations have begun to consider experiments with the conference model, which, after all, has remained static for decades—why shouldn’t it change in the face of both new technological options and new environmental imperatives?


Aviation is a large fraction of city greenhouse gas inventories

For cities that are honest enough to count aviation at all, the aviation sector is a large fraction of greenhouse gas inventories.

For example, in Seattle’s official 2016 greenhouse gas inventory (.pdf), air transportation at the two airports is responsible for 1.25 million metric tons of carbon dioxide equivalent (CO2e) emissions (21% of all emissions). This represents a rapid increase from 2008, when air transportation was only 0.99 million metric tons CO2e (16% of all emissions).

Thus, in just 8 years, the fraction of Seattle’s emissions attributable to aviation jumped by more than 30% (increasing by 5 percentage points from 16% in 2008 to 21% in 2016 of all CO2e emissions).

In Seattle, air transportation grew from 16% of emissions in 2008 to 21% of emissions in 2016.

In light of such statistics, it requires some courage for cities to address aviation. Seattle’s 2013 Climate Action Plan in part deflects responsibility for the aviation sector: “Air travel is not a central focus of this Plan. Most of the actions to address aviation’s impact on the climate are beyond the reach of any individual city.” But, it does describe some small steps in reducing travel by city employees.

More importantly, in discussing what others are doing, Seattle lays out a vision that includes not only technology change and alternate fuels, but also changes in aviation demand: “Reducing unnecessary trips is a key strategy for reducing the impact of air travel on the climate. New communication technologies have the potential to optimize business travel, which is a significant source of air travel emissions.”

Like Seattle, the ambitious carbon neutrality plan for Paris recognizes the large contribution of aviation emissions. As with Seattle, one can see the pain that it causes city planners in Paris to address aviation, because the impact is so very large. If one excludes aviation transportation, the total emissions for Paris are 19.6 million metric tons CO2e. But when aviation is included, the total rises by 6 million tons to 25.6 million metric tons CO2e. Aviation is 23% of the total.

In Paris, air transportation is 23% of greenhouse gas emissions.

In communicating this impact, the chart below from the Paris plan strikes an understandable compromise, not hiding the aviation emissions, but not quite ready to include them in the official statistics (because, as with Seattle, city planners may in part attribute air transportation to forces beyond their control). So, quite reasonably, the chart provides the statistics a reader might need, with and without air transportation.

For city governments, seeking to report this issue correctly without overstating their own responsibility, a useful and balanced reference is the “Global Protocol for Community-Scale Greenhouse Gas Emission Inventories: An Accounting and Reporting Standard for Cities” (.pdf). This protocol notes that Intergovernmental Panel on Climate Change (IPCC) guidelines for national accounts require the reporting of both domestic and international air travel emissions, but they do not require countries to include the international air travel emissions in official totals. In other words, individual countries need not take full ownership of international air travel emissions, which are supposed to be addressed by a separate UN process, but it would be wrong for countries to hide or disguise these emissions. All air travel emissions still must be reported.

In the same spirit, the protocol for cities requires the inclusion of airborne trips within the geographic boundary (such as helicopters) and, importantly, “emissions from flights departing airports that serve the city.” The protocol recognizes some complexity, because not all flying at such airports is attributable to people from the city itself. A city’s emissions inventory can indicate whether the airport serves local, national, or international travelers. So long as transparency is maintained, the protocol says, “cities may report just the portion of scope 3 aviation emissions produced by travelers departing the city.” Just as in the Paris example, it might be understandable to exclude part of the airport’s air travel emissions from certain official tallies, so long as all emissions are reported clearly somewhere in public reports. The protocol says, “Cities shall transparently document the methods used in the inventory reports.”

In contrast with Seattle, Paris, and the protocol for cities, the Boston climate action plan hides the impact of aviation. With no justification, the methdology report (.pdf) states that it counts energy related emissions “not related to air travel.” The city’s web page boasts that Boston decreased total emissions by 4% from 2016 to 2017, without noting that the rapidly growing air travel sector was excluded. The Boston Green Ribbon Commission website gives a rosy picture of city progress. Its high-profile Carbon Free Boston report (.pdf) sets goals for most sectors other than air travel. The one-sentence comment on air travel is buried in the report: “Our analysis notably omits air travel at Logan airport and the consumption of goods and services.” We have requested by email further information on how air travel from Logan Airport may be counted at any future time, with no response. As noted above in the examples of Seattle, Paris, and the protocol for cities, one might understand that not all Logan Airport emissions would be included in all official tallies, but there is no basis for pretending the airport does not exist.

In Boston, with no justification, air transportation is excluded from greenhouse gas inventories. As a consequence, official statements on climate neutrality plans are misleading.

For cities, sensible protocols have been established for greenhouse gas inventories, which are used in monitoring and goal-setting in this time of climate crisis. For cities with the courage to look at this issue, aviation turns out to be responsible for a large fraction of total CO2e emissions, exceeding one fifth of emissions in major cities. Climate action plans and greenhouse gas inventories that hide aviation emissions, simply omitting them from public accounts as if they did not exist, fall short of accepted accounting standards and reasonable public expectations of honest reporting, harming serious efforts to address climate change.