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CORSIA and the 0.1%

The news in October that ICAO had reached an agreement on aviation emissions was welcomed by most in the aviation community. Congratulations poured in for what various spokespeople referred to as a ‘historic’, ‘cutting-edge’ and ‘critical’ agreement. Among those welcoming the news from Montreal was the European Business Aviation Association (EBAA) and the US equivalent, the National Business Aviation Association (NBAA). That is hardly surprising. For them it was a good agreement. You see, most business aviation operators will be exempt from CORSIA. The agreement states that operators emitting less than 10,000 tonnes of CO2 emissions from international aviation per year, or weighing less than 5,700 kg are exempt from CORSIA. Almost all business aviation operators fall under one of those categories, if not both. However, despite individual business aviation operators generally being small, business aviation as a whole is responsible for 2% of all aviation CO2 emissions. Unfortunately, given that CORSIA applies only to emissions from international flights, information is not available on business aviation’s contributions to international CO2 emissions. It may not be unreasonable to assume the 2% figure applies for both domestic and international emissions. Based on a 2013 study, 2% is also roughly the share of international emissions generated respectively by Canada, India, Italy and the Netherlands, and significantly more than many, many other countries including Switzerland, Argentina, Russia, Mexico and South Africa. It is notable that most of these countries have signed up to participate in the scheme voluntarily from 2021. From 2026 the requirements established under CORSIA will become mandatory, with some exceptions. The main exemptions are States that contributes less than 0.5% of total revenue tonne kilometres (RTKs) or are classified under various categories of undeveloped countries (eg, Small Island Developing States). Oh, and business aviation. The official reason for business aviation’s exemption is to avoid the administrative burden. Airlines operating under CORSIA will be required to measure and report their emissions, and to purchase offsets. In Europe, where business aviation is required to participate in the flagship environmental scheme there, the EU Emissions Trading Scheme (ETS), many small operators have reported that they have been overwhelmed with the requirements of complying. We find this justification puzzling. While it may take some imagination to devise a compliance scheme that has a low administration cost (learning lessons from the ETS’s Small Emitter’s Tool), it is not impossible. ICAO gave up too easily. Business aviation’s problem is that many operators are very small, operating one or two aircraft only. However, an organisation such as EBAA or NBAA could take more of a role in helping these companies, perhaps by operating a centralised service that allow small operators to benefit from economies of scale. The exclusion of business aviation from CORSIA becomes even more puzzling when compared with the reason for CORSIA’s other main exclusion: States with undeveloped economies or small aviation industries. Requiring these States to participate could threaten the development of their economies as well as airline industries, so the argument goes. These are countries where the industry and passengers are less able to absorb the potential cost of CORSIA. Compare that with business aviation, used by some of the wealthiest individuals on the planet. Business aviation seems to have slipped under the radar here. It can barely hide its glee. Following the announcement of the establishment of CORSIA, a press release from NBAA noted that ‘the good news is that CORSIA will apply only to international flights, and a mere 160-200 business aircraft operators worldwide are expected to be affected.’ Given the weak basis for their exclusion, perhaps a more subdued response would have been more appropriate.

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