The flying elephant in the room (Issue #1)

Hey! I’m Chris. When I worked for the United States (US) Federal Aviation Administration, I helped create the environmental modeling tool that’s now required for aviation environmental compliance across that country. I also participated in some of the first International Civil Aviation Organization discussions to create a global carbon dioxide (CO₂) standard for aircraft.¹

This issue is not about that stuff.

The “row” started in 2012… or did it?

On January 1st of 2012, the European Union (EU) did something that outraged airlines and their home countries across the globe: It unilaterally added international aviation to its Emissions Trading System (ETS) carbon market, covering all CO₂ emissions from flights that depart from or arrive to EU member states. The US had tried to block the EU’s action the prior year… and failed.² In response to the 2012 addition of international aviation to the EU’s ETS, China blocked its airlines from buying Airbus aircraft (according to Airbus, anyway³ ) and over 26 countries dubbed “the coalition of the unwilling” met in Moscow that February to discuss “options for retaliatory action against the EU.”⁴

The EU had launched the ETS in 2005 as a “cap and trade” system to limit allowable greenhouse gas emissions and enable affected entities to trade “carbon credits” — the rights to emit specific amounts of greenhouse gases.⁵ The first phase of the ETS covered only power generators and other “energy-intensive industries;” adding international aviation to this, especially without the express written prior approval of other countries, was supposed to be a no-no. That’s because, for decades, most of the world's countries (193 to date) had established aviation environmental standards through a little-known body of the United Nations known as the International Civil Aviation Organization (ICAO).⁶ ICAO member countries are supposed to "promulgate" (formally establish) aviation environmental standards in their home countries only after those standards are agreed by ICAO -- and there was no ICAO standard for an international aviation CO₂ market on January 1st of 2012.

22 years of talking

The idea of a carbon market for international aviation goes back to at least 1998. That year, ICAO released resolution A32-8 to study emissions-related charges, taxes, and emissions trading⁷ , all known in ICAO parlance as “market-based measures” (MBMs). In 2010, ICAO released resolution A37-19 resolving to research the feasibility of establishing global market-based measures for aviation.⁸  

The EU’s 2012 addition of international aviation to its ETS accelerated discussions on MBMs rather severely. In fact, a European Commission staff working document gently stated the following in 2013⁹ :

English translation: ICAO should commit in 2013 to implement a global MBM for aviation by 2020… or else! 

And indeed, ICAO in 2013 released resolution A38-18, which stated that ICAO "[d]ecides to develop a global MBM scheme for international aviation.”¹⁰ In 2016, ICAO began developing the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) for launch in 2020,¹¹ to enable “carbon-neutral growth” from that year forward.¹²

22 years of discussions to launch a global carbon market for aviation. ICAO sure took its fill of sweet, sweet time.

CORSIA works by requiring aircraft operators subject to CORSIA to purchase and then “cancel” specific amounts of “eligible emissions units” – that is, CO₂ carbon credits available in a CORSIA-approved global carbon market – every year.^{13  14} Purchasing a credit is supposed to help provide funding to projects around the world that avoid, reduce, or remove CO₂; the price of each credit is supposed to be set by the supply of credits vs. the demand in the carbon market. The “cancellation” of such credits (also called “retirement” in some sectors) is supposed to occur after an independent verifier documents that the representative CO₂ has indeed been avoided, reduced, or removed by a project. Cancellation of credits could happen instantly or could instead take years, depending on the type of project.

Aviation’s decarbonization challenge… and cost

In October of 2021, over 300 airlines carrying a majority of the world's air traffic committed to "achieve net zero carbon by 2050.”^{15  16} But even as the industry made that commitment, aviation CO₂ emissions were continuing to grow. In 2022 alone, those emissions were almost 800 million metric tons¹⁷ : about the same amount of CO₂ released by the entirety of Canada, or Germany, or Mexico, or Saudi Arabia that same year.¹⁸ Also that year, ICAO published a report on the feasibility of a “long-term aspirational goal” (LTAG) for global aviation CO₂ reductions.¹⁹ This report stated that aviation CO₂ emissions in the year 2050 (in the LTAG “mid” traffic forecast) could be over 1.5 billion metric tons — more than that released by Brazil or Indonesia in the year 2022.²⁰

ICAO’s most ambitious technology, operations, and “sustainable aviation fuels” (SAF) deployment scenario in the LTAG document, named “IS3,” leaves 203 million metric tons of “residual” CO₂ that would have to be offset every year by 2050 for global aviation to reach net zero carbon. For context, that’s roughly the same amount of CO₂ that Qatar or Ethiopia produced in 2022. ICAO’s least ambitious technology, operations, and SAF deployment scenario, named “IS1,” leaves almost one billion metric tons of “residual” CO₂ that would have to be offset every year by 2050 —  about the same amount of emissions released by Japan or Iran in 2022.

Imagine having to “cancel” the entirety of Japan’s or Iran’s CO₂ emissions every single year. Yes, that’s what CORSIA is theoretically intended to make possible. If global advancements in technology, operations, and SAF don’t measure up to that “least ambitious” LTAG IS1 scenario, then the carbon emissions needing yearly “cancellation” will be even higher.

Now, where exactly will we find enough offsetting projects to cancel that much CO₂… every single year? After all, international aviation isn’t the only sector that has committed to “net zero”…

Of course, none of these CO₂-reducing efforts come for free. In the LTAG IS1 scenario, the global aviation sector (including national governments, airlines, manufacturers, fuel producers, etc.) would have to invest the following cumulative amounts of money between 2020 and 2050²¹ :

• $165 billion to $560 billion in new aircraft technology

• $53 billion in fuel-saving operational techniques

• $1.2 TRILLION in SAF investment, plus an additional $1.1 TRILLION in “incremental cost” (vs. the cost of fossil jet fuel) borne by the airlines to purchase SAF

But hey, the aircraft operators would also save about $1 trillion in total through reduced fuel costs (due to new aircraft technology and operational techniques) so their incremental costs basically balance out!

In the LTAG IS3 scenario, the global aviation sector would have to invest the following cumulative amounts of money between 2020 and 2050²² :

• $335 billion to $1.9 trillion in new aircraft technology

• $181 billion in fuel-saving operational techniques

• $3.2 trillion in SAF and other fuels investment, plus an additional $4 trillion in airline incremental cost and an additional $125 billion in airport infrastructure investment

A “trillion” sure sounds like a big number. (Cue the “a trillion dollars by 2050 isn’t actually all that much money” critics…) For context, the gross domestic product (GDP) of the United States of America was $25 trillion in 2022, according to the World Bank.²³ Or put another way, $3.2 trillion in SAF investment between 2020 and 2050 means investing, on average, the entire 2022 GDP of Puerto Rico, or Angola, or Kenya, or the Dominican Republic every year within that 30-year time frame.

Oh: by the way, CORSIA compliance for airlines is an additional cost on top of all of the above.

And also by the way, the entire text above only addresses CO₂. There are whole other worlds of sustainability, from water to air quality to human rights, that “net zero carbon by 2050” doesn’t even begin to cover.

Questions for you to think about

• If buying carbon credits is cheaper than buying SAF or new aircraft technologies, would the natural response of airlines be to "decarbonize" through CORSIA offsetting rather than through new fuels? What kinds of offsetting projects would be needed to cancel all the associated CO₂ emissions?

• Does the global aviation sector "deserve" the investment that would be needed to achieve net zero carbon in 2050? Yes: we as a global society can invest in more than one thing at once, but we do have limited resources needing allocation to many causes.

• Perhaps you believe that the numbers in this article are entirely overblown — after all, it’s difficult to forecast how the aviation sector will perform even one year in advance, much less in the year 2050. So, let’s say that the actual dollar cost and offsetting requirements are “only” 1/10th the numbers presented in this article. If so, would your answers to the above questions change?

• Finally: Is net zero carbon by 2050 really the way to achieve authentic global aviation sustainability? What does “authentic global aviation sustainability” look like to you?

Where you can learn more about authentic sustainability

FIRST: Follow these awesome folks on LinkedIn:

• Heather Luna of keduzi: workshopping pro-connectedness and anti-oppression as a way of life

• Lavinia Muth: deconstructing the (un)sustainable fashion industry

• Dr. Vidhya Shankar, Ph.D: decentering whiteness in evaluation of non-governmental organization projects

SECOND: Forward this issue to people you know who work in "sustainable" aviation and other green technology sectors.

Got something to say to me?

Hit the “reply” button and give me a piece of your mind.

Introductory image from “Dumbo” by Walt Disney Productions, released on October 23, 1941.

1  International Civil Aviation Organization. “ICAO Council adopts new CO2 emissions standard for aircraft.” March 6, 2017. Last accessed: June 15, 2024. Original link. Archived link.

2  BBC. “US rejects European Court ruling on airline emissions.” December 21, 2011. Last accessed: June 15, 2024. Original link. Archived link.

3  The Guardian. “Russia fires first shot in EU aviation emissions trade war.” February 22, 2012. Last accessed: June 15, 2024. Original link. Archived link.

4  POLITICO. “ETS opponents outline retaliatory measures.” February 22, 2012. Last accessed: June 15, 2024. Original link. Archived link.

5  European Commission. “Development of EU ETS (2005-2020).” Last accessed: June 15, 2024. Original link. Archived link.

6  International Civil Aviation Organization. “The History of ICAO and the Chicago Convention.” Last accessed: June 15, 2024. Original link. Archived link.

7  International Civil Aviation Organization. “Resolutions Adopted at the 32nd Session of the Assembly - Provisional Edition.” Last accessed: June 15, 2024. Original link. Archived link.

8  International Civil Aviation Organization. “Resolution A37-19: Consolidated statement of continuing ICAO policies and practices related to environmental protection – Climate change.” Last accessed: June 15, 2024. Original link. Archived link.

9  European Commission. “Commission Staff Working Document - Executive Summary of the Impact Assessment Accompanying the Document ‘Proposal for a Directive of the European Parliament and of the Council amending Directive 2003/87/EC establishing a scheme for greenhouse gas emission allowance trading within the Community in view of the implementation by 2020 of an international agreement applying a single global market-based measure to international aviation emissions.’” 2012. Last accessed: June 15, 2024. Original link. Archived link.

10  International Civil Aviation Organization. “Doc 10022 - Assembly Resolutions in Force (as of 4 October 2013),” page I-72. Last accessed: June 15, 2024. Original link. Archived link.

11  International Civil Aviation Organization. “Resolution A39-3: Consolidated statement of continuing ICAO policies and practices related to environmental protection – Global Market-based Measure (MBM) scheme.” Last accessed: June 15, 2024. Original link. Archived link.

12  International Civil Aviation Organization. “Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) Frequently Asked Questions (FAQs) (updated as of April 2024),” item 1.6. Last accessed: June 15, 2024. Original link. Archived link.

13  International Civil Aviation Organization. “Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) Frequently Asked Questions (FAQs) (updated as of April 2024),” item 2.14. Last accessed: June 15, 2024. Original link. Archived link.

14  International Civil Aviation Organization. “ICAO document - CORSIA Eligible Emissions Units.” March 2024. Last accessed: June 15, 2024. Original link. Archived link.

15  International Air Transport Association. “Our Commitment to Fly Net Zero by 2050.” Last accessed: June 18, 2024. Original link. Archived link.

16  International Air Transport Association. “IATA - Members.” Last accessed: June 18, 2024. Original link. Archived link.

17  International Energy Agency. “Aviation - IEA.” Last accessed: June 18, 2024. Original link. Archived link.

18  European Commission. “GHG emissions of all world countries - 2023 report.” Last accessed: June 18, 2024. Original link. Archived link.

19  International Civil Aviation Organization. “Report on the Feasibility of a Long-Term Aspirational Goal (LTAG) for International Civil Aviation CO2 Emissions Reductions.” March, 2022. Last accessed: June 18, 2024. Original link. Archived link.

20  Ibid. 18.

21  International Civil Aviation Organization. “Report on the Feasibility of a Long-Term Aspirational Goal (LTAG) for International Civil Aviation CO2 Emissions Reductions. Appendix R1 - Summary Sheets.” March, 2022. Last accessed: June 18, 2024. Original link. Archived link.

22  Ibid. 21.

23  The World Bank. “Gross domestic product 2022.” Last accessed: June 18, 2024. Original link. Archived link.