The group delaying aviation climate action worldwide (Issue #6)

Guess who.

Author

Chris Musei-Sequeira
September 26, 2024

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Yes: The body where nearly all aviation standards originate is the same body delaying climate action — and other environmental action — for aviation worldwide.

I’m not the type of person to bury the lede.

ICAO is a body of the United Nations that exists to "harmonize" aviation safety, environmental, air traffic, and other standards so that all the world's airlines experience roughly the same regulatory environment. Over 190 countries participate, with the United States of America (USA) being among the most powerful.

I sat in numerous ICAO Committee on Aviation Environmental Protection (CAEP) meetings during my time as a USA Federal Aviation Administration (FAA) employee. My focus area was ICAO CAEP Working Group 3, which helped set standards for air emissions from aviation. People in those meetings repeatedly said that the role of ICAO CAEP was not to push the aviation sector's environmental performance, but to "prevent backsliding."

"Prevent backsliding." Actual quote.

Meaning:

  1. See where the global aviation industry's environmental performance is already going

  2. Establish ICAO environmental standards and recommended practices (SARPs) that are highly likely to be met by the time they go into effect

Why not establish more-aggressive "technology-forcing" environmental standards for aviation?

Well, people at ICAO meetings told me that doing so could threaten aviation safety. Because I don't have a safety background, I really couldn't challenge their claim. The FAA also has a habit of throwing the “safety card” around — but that’s a topic for another day.

Functionally, ICAO's "prevent backsliding" approach to aviation environmental standard-setting makes ICAO the lowest common denominator in global aviation regulations. Whatever ICAO does is quite simply a floor. Airlines, aircraft manufacturers, and their home countries will insist that standards impacting aviation originate at ICAO first. ICAO standard-setting is highly formalized and typically takes years.

Countries daring to implement an environmental regulation that's stronger than an ICAO SARP risk extra-judicial punishment from countries whose airlines are affected. Such punishment has been meted out before. I was an employee at the FAA’s Headquarters in Washington, D.C. in 2012 when the European Union (EU) did something that outraged airlines and countries worldwide: It added international aviation to its Emissions Trading System (ETS) cap-and-trade scheme, covering all carbon dioxide (CO2) emissions from flights to and from the EU. The United States tried to stop this action and failed, because the EU Court of Justice ruled that the EU's action was in compliance with international law.1

The result was a global aviation trade war.

  • China blocked its home airlines from buying Airbus aircraft2

  • The USA airline trade group Airlines for America said that its members would comply with the EU’s ETS "under protest"3

  • Over 26 countries dubbed “the coalition of the unwilling” met in Moscow to discuss “options for retaliatory action against the EU"4

Countries around the world, particularly the USA, insisted that aviation emissions "market-based measures" (MBMs) like carbon markets should be coordinated through ICAO.

After talking about MBMs since at least the late 1990s, ICAO finally moved forward with a global MBM for aviation's CO2 emissions. This system, launched in 2016, is ICAO's Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). CORSIA is currently voluntary, but airlines are mandated to offset specific amounts of CO2 every year beginning in the year 2027. I talk about CORSIA at length in my article “The Flying Elephant in the Room.”

I am convinced that CORSIA would have never happened if not for the EU's unilateral action to add international aviation to its ETS in 2012. And yet, I am unimpressed with CORSIA specifically, and carbon offsetting generally, at a fundamental level. I've read many posts and articles about the problems with carbon offsetting: from issues with monitoring, reporting, and verification (MRV); to threats to Indigenous and peasant peoples throughout the Global South; to outright fraud. My go-to source for compilations of such information is REDD Monitor.

The above is just one of multiple reasons why I no longer look to ICAO for leadership in any aspect of aviation and the environment.

Where to find the sustainability perspectives you’ve been missing

FIRST: Forward this issue to people you know in the sustainability industry — they’ll probably say a thing or two in response!

SECOND: Follow on LinkedIn:

THIRD: Subscribe to the “We Are LaCH” podcast, where Heather and Lavinia and I host discussions on decolonization — particularly in the context of the sustainability industry.

Got something to say to me?

I’m Chris, the Principal of CJSC, LLC, and I’m (un)learning along with all of you — so hit the “reply” button and give me a piece of your mind!

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My name is Chris Musei-Sequeira, and I use he/him pronouns. My mother was born in Trinidad and Tobago as a descendant of African slaves brought to the islands during the time of European colonization. She came to the United States of America (USA) at the age of 10. My father was born in India, in Mumbai, and raised Catholic and English-speaking; he has a Goan background and describes himself and his family as Brahmin. He came to the USA for his graduate studies, where he met my mother.

My sister and I were born in the USA and lived a middle-class life in the suburbs of multiple American cities. I studied aeronautical engineering and technology policy in university, then worked at the Federal Aviation Administration and as an aviation consultant. I've lived in cities up and down the USA East Coast since the age of 18.

I thank Heather Luna and Lavinia Muth for showing me the importance of publicly expressing positionality. Because of our positionality, all of us are very familiar with some aspects of the world while having no idea of other aspects.

Introductory image: Jack Delano. (1941, July). "Airliners lined upon the field. Municipal airport, Washington, D.C.” Retrieved September 21, 2024 from https://www.loc.gov/resource/fsa.8c06386/. Archived Link.

1  BBC. (2011, December 21). US rejects European Court ruling on airline emissions. Retrieved September 21, 2024 from https://www.bbc.com/news/business-16282692. Archived link.

2  Phys dot org. (2012, January 5). Chinese airlines 'won't pay EU carbon charge'. Retrieved September 21, 2024 from https://phys.org/news/2012-01-chinese-airlines-wont-eu-carbon.html. Archived link.

3  Ibid. 2.

4  Keating, D. (2012, February 22). ETS opponents outline retaliatory measures. POLITICO. Retrieved September 21, 2024 from https://www.politico.eu/article/ets-opponents-outline-retaliatory-measures/. Archived link.