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ICAO’S CORSIA: Pie in the Sky?

This month, the Aviation Intelligence Reporter has two articles about CORSIA and what it means. The ICAO Assembly meets later in September and CORSIA is on the agenda. We think that it is time to look analytically, rather than as cheer-leaders, at CORSIA and what it means, and does not mean. Below is one of the pieces we are running, in full. It is by Chris Lyle, the CEO of Air Transport Economics in Montreal.

ICAO’S CORSIA: Pie in the Sky? – By Chris Lyle, CEO Air Transport Economics

2016 was quite a year. We had the Brexit referendum in the UK, the election of Donald Trump in the US… and the decision to implement CORSIA by ICAO. Yes, there are commonalities! CORSIA (Carbon Offsetting and Reduction Scheme for International Aviation), as with the Brexit vote, has generated a mindboggling administrative jungle of complexity and resource commitment without any lucid assessment of benefit. At least Brexit has only taken 3 years so far, ICAO’s emissions mitigation mandate stretches back to the 1997 Kyoto Protocol. And CORSIA has been fake news from its inception, given the ‘R’ of Reduction. There was never any intent to reduce international aviation’s CO2 emissions through this market-based measure. The aim was ‘carbon neutral growth’, which will not be achieved, even with 100% implementation, because of various embedded exemptions. And IATA has shown that the anticipated offset costs under CORSIA will not reduce traffic growth to any extent. ICAO now admits that carbon emissions from international aviation could treble by 2045.

An alternative fact is that CORSIA is touted as a climate panacea. The inconvenient truth is that, while certainly a step forward in terms of the evolved database, CORSIA reflects the lowest common tolerability amongst 193 countries. It will be minimally effective and bureaucratically costly. With offsets cheaper than purchasing yet-to-be defined sustainable fuels, where is the incentive? We are still waiting to hear from ICAO on whether it will continue to accept Brazil’s sugar cane, Indonesia or Malaysia’s palm oil, or Saudi Arabia’s ‘low carbon’ oil as sustainable aviation fuels. Some of ICAO’s inadequacies in relation to emissions mitigation are finally coming into the public eye. The Guardian has addressed the lack of transparency in ICAO’s deliberations and The Economist has expressed concern that ICAO has been captured by producer interests.

CORSIA is destined to fritter away over the years. It is fragile and vulnerable. It is founded on ICAO Standards – well-known for the ‘filing of differences’ or not being followed until subjected to audit (if at all). Related fake news is that CORSIA will be mandatory from 2027 – it is not legally binding for any country. CORSIA involves the first ever application of Standards to an economic matter rather than ones of safety, security and facilitation. All earlier economic regulation initiatives have not passed the drawing board. There will be no substantive comeback on deficiencies in the form of penalties or sanctions. ICAO cannot deal with States in arrears to its operating budget – try banning an operator from your territory for not applying a CORSIA Standard.

Offsetting is being increasingly questioned. The EU does not envisage continuing use of offset credits after 2020 – except for CORSIA. Former UNFCCC Executive Secretary Christiana Fugueres has pointed out that offsetting ‘is not a silver bullet, nor an alternative to the deep and decisive emissions reductions that economies and communities have to make now and into the future’. In a keynote address to the ICAO Environmental Symposium in May, Luis Alfonso de Alba, the UN Secretary-General’s Special Envoy for the UN Climate Action Summit to be held in September, called for greater ambition by ICAO in the context of the aim of global net carbon zero emissions by 2050. ‘Efforts taken by the sector, particularly the CORSIA agreement, need to be scaled up in a very substantial manner’ he noted. This call for urgency fell on deaf ears, with the ICAO Secretariat’s immediate response being to press even harder for the full implementation of CORSIA, which is presently designated to run until 2035.

Despite its SG signing the Joint Appeal from the UN System for the coming Climate Action Summit for ‘urgent action to limit global temperature rise to 1.5°C above preindustrial levels’ the Secretariat was remarkably passive in drafting the ICAO Council’s reports to the coming Assembly in September. These reports, docilely approved by the Council, are of the view that ICAO has taken all necessary measures to respond to climate change and does not need to respond specifically to the Paris Agreement, or the IPCC Special Report on 1.5°C, or calls for greater ambition.

Therefore, despite calls by industry, NGOs and European States, the feasibility of developing a long-term emissions mitigation goal, first proposed in 2010, is to be postponed for yet another triennium. ICAO is apparently once again awaiting leadership from industry, which IATA’s de Juniac says is ‘hellbent’ on a long-term emissions reduction strategy but is unlikely to be too happy with one which is not of its own making. In the meantime ICAO is retaining its long-term fuel efficiency improvement goal of 2% per annum through to 2050 while at the same time forecasting that ‘even under the most optimistic scenario’ the figure is likely to be 1.37%. On CORSIA eligible fuels there are to be ‘further proposals on strengthened sustainability criteria by the end of 2023’. Finally, there is no significant mention of greenhouse gases other than CO2.

ICAO continues to discourage greater mitigation ambition by retaining an exclusivity provision for CORSIA. This was originally aimed at the European Union with its more effective Emissions Trading System which, with full operation, would produce a greater mitigation impact than the worldwide one of CORSIA. IATA, the US A4A, the US administration and others have attacked proposed supplemental market-based measures. The President of the ICAO Council has not exactly maintained his neutrality either, publicly expressing his concerns regarding environmental taxes that some countries are either considering or have already started introducing in Europe. On the UN Secretary-General’s coming Summit the report to the ICAO Assembly says defensively (and in the last phrase indefensibly) that ‘ICAO has been engaged in the process toward this Summit, with the aim of maintaining ICAO’s leadership role in all issues relating to international aviation and climate change, by highlighting ICAO’s achievements, and seeking clear recognition of ICAO’s mandate for international aviation, which will complete the ambitions set forth by the Paris Agreement’.

At the coming ICAO Assembly, departing President Aliu will no doubt be anxious to protect his legacy, a primary element of which is CORSIA. European States, having been bêtes noires on environmental matters at several previous Sessions of the Assembly, are paranoid at being blamed for collapse of CORSIA and will do whatever to avoid carrying that can. ICAO’s basket of emissions mitigation measures (technology, sustainable fuels, operations and CORSIA) will contribute pro rata less than any of the first Nationally Determined Contributions to which 184 Parties have committed under the Paris Agreement as at the end of July 2019, let alone any more stringent measures reported to be coming for the next round of commitments in 2020. Thus the international aviation sector, with its separate treatment, is predicted to take a substantially increasing share of the global carbon emissions budget. Targeted emissions reductions for aviation may understandably be lower than for other sectors due to the current non-availability on scale of sustainable fuels, but if Paris Agreement targets are to be achieved, economic or explicit rationing of aviation may become necessary.

The world cannot afford to wait and see how CORSIA goes. There is a pressing need to step back and take a broad view in the context of tourism, trade, economic development and overarching emissions imperatives. Why should a country with greater ambition not be allowed to realise it? How can taking mitigation action beyond CORSIA, particularly on emissions below CNG or inclusive of CORSIA but with greater ambition, be ‘overlapping or duplicative’, as IATA claims? Taxation may not be an unqualified answer, but in this era of the circular economy why could not at least part of tax/charge/fee revenues be hypothecated to aviation emissions mitigation? Those from CORSIA are not. Should focus move from questionable bio-fuels to the promise of synthetic/power-to-liquid? While ICAO is a undoubtedly a key player, to what extent is it the right forum for defining such aspects as criteria for emissions units or sustainable fuels?

European and other concerned States need to show some backbone in the face of the powerful industry and ICAO communications machines, whose credibility is questionable in this context through the extraordinary claims that aviation directly supports no less than 15 of the UN’s 17 Sustainable Development Goals. The industry, its customers and the climate deserve better. We need to surmount the silo mentality and move from ‘what a good job we/you are doing’ to seeking the answers to some hard questions.

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