As the date of the European Union’s (EU) controversial implementation of its aircraft Emissions Trading Scheme (ETS) nears, the International Civil Aviation Organization (ICAO) is moving forward with plans for a global carbon dioxide (CO2) standard for aircraft it hopes to have developed by 2013. The final standard that emerges is likely to parallel ICAO’s highly successful “Stage” noise standards, according to Eli Cotti, director of technical services for NBAA. association’s interests, and those of various other business aviation groups, are being represented by the International Business Aviation Council (IBAC), an official ICAO observer.

Over the summer ICAO held multiple workshops designed to help its 190 member states produce national action plans for reducing CO2 emissions from international civil aviation. Various ICAO observer stakeholders provided technical assistance at these meetings. The action plans are due to ICAO by June 2012, six months after the EU’s ETS takes effect. The goal of ICAO’s standard is to stabilize civil aircraft emissions at 2020 levels and thereafter achieve a 2-percent annual increase in fuel efficiency by 2050. ICAO’s Committee on Aviation Environmental Protection (CAEP) is developing the standard.

The ETS is currently under various legal challenges and is seen as violating various international civil aviation accords, including Article 15 of the Chicago Convention (1996). The article states that any environmental charges “should be related to cost” and “should not discriminate against air transport compared to other modes of transport.”

Cotti calls the ETS a “market-based” solution designed to encourage aircraft operators to modernize their fleets, but is of the opinion that only an ICAO standard will be truly effective. “The business aviation community wants a standard that is applicable on a global framework,” Cotti said. “Without an ICAO standard we end up with a patchwork of different standards that vary from state to state,” Cotti said. “The EU went its own way and now we need to deal with it.”

Unilateral action on environmental aircraft charges dates back to 1994 when the UK implemented an Air Passenger Duty, a charge Ireland copied in 2009. This year Australia will implement a $930 million carbon tax fuel surcharge on domestic airlines.

Voluntary Environmental Programs

Elements within business aviation have already experimented with market-based solutions voluntarily. Bombardier offers a Carbon Offset program through JPMorgan ClimateCare that collects approximately $30 to $70 per hour depending on the size of the aircraft flown. In 2008, Embraer launched the Embraer Carbon Offset (ECO) module for enrollees in its Embraer Executive Care (EEC) program that bundles ECO and EEC charges. NetJets Europe, in partnership with EcoSecurities, launched a carbon offset program in 2007 designed to make its fleet carbon neutral by 2012. By last year more than 80 percent of the company’s fractional owners were participating in the program, which funds Kyoto-level offset projects including wind-power and hydropower projects in China and cogeneration projects in Brazil and Nicaragua. NetJets Europe reported that 73 percent of its flights were being offset.

Cotti predicted that any future CO2 standard would likely parallel ICAO’s successful development of the “Stage” noise standards that business aircraft OEMs have embraced. “As soon as a new stringency is announced, the business aviation community wants to be doing the best thing. They make the choice today and take it into the future. Right now, Stage 4 is the current state-of-the-art requirement for noise, and some manufacturers have actually gone back and certified in-production aircraft for Stage 4.”

ICAO began to tackle the aircraft noise issue in the 1960s and IBAC notes that “aircraft coming off the production line today are about 75 percent quieter than they were 40 years ago” and that “today’s business aircraft are about 7 dB quieter than most commercial aircraft.”

In 2009, IBAC reaffirmed its support to aviation emissions reduction, noting that it and its members “are fully prepared to assume a shared responsibility to seek ways to mitigate the impact of aircraft on the environment and are willing to take a leadership role to address emissions from business aviation on a harmonized worldwide basis.” This included the development of new and cleaner technology.

Historically, the aviation industry, including business aviation, has embraced any market-based solution that improves efficiency and saves money. Today’s jetliners are 70 percent more efficient than the 707s and DC-8s of the 1960s. Aviation Partners of Seattle estimates its “blended winglets” have saved the airlines more than 2.5 billion gallons of fuel by improving aircraft performance and today just about all new business aircraft come equipped with winglets or have aftermarket solutions available for retrofit. The new generation of business jet engines under development or coming on line, including GE’s TechX, are significantly more efficient and cleaner than the engines they are replacing.

Multifaceted Approach to Emissions Reduction

Specifically, IBAC promotes a “multi-path” approach to emissions mitigation that includes operator emission-management programs introduced in incremental stages commencing with international operations; reduction of carbon emissions in business aircraft operations; design of low-emissions engines and airframes that are technically feasible and economically reasonable; more efficient ATC via new technology and operational procedures; implementation of best practices for operators; reasonable NOx and CO2 emission certification standards for aircraft in ICAO Annex 16; harmonization with ICAO policies, standards and recommended practices and guidelines; and improved emissions data collection programs.

Cotti said the current sticking point on getting the CO2 standard done is the development of universally accepted metrics that need to be hashed out by a CAEP steering group. Specifically, there is disagreement on what portion of a flight should be measured. Cotti hinted that developing a universally accepted metric for CO2 based on the recommendations of the CAEP working groups might not happen by 2013.

Whatever metrics are adopted need to be technology, and not aircraft mission, specific, Cotti said. “We want to make sure it is fair and equitable. You can’t segregate how you use an airplane. A Gulfstream executive transport one day can be a Defense Department special-mission airplane the next. Developing a standard should be utilization independent.”

Value of Biofuels

Cotti noted that a CO2 standard is just one item in “a basket of measures” ICAO will use to achieve its goal of carbon-neutral growth for aviation and that CO2 emission measurement goes significantly beyond engine technology. It encompasses aerodynamic improvements, ATC improvements, and the increased use of biofuels.

ICAO is also developing standards for other aircraft emissions, including nitrous oxide (NOx). Last year CAEP recommended a 15-percent reduction in large jet engine NOx and a 5- to 15-percent reduction in smaller engines certified after 2013.

Despite the stricter emission standards in the works, Cotti thinks older aircraft will remain viable thanks to a likely combination of market-based measures and the introduction of biofuels. “The sooner we can get alternative fuels into the stream, the sooner we can increase that capability. By 2050 it will be a substantial part of the solution. Flights have already successfully been conducted with a 50-50 blend of biofuels and jet-A, and someday we could see biofuels making up 50 percent of the total amount of aviation fuel consumed,” he said.

Currently, most biofuels are refined for ground vehicles and are soybean-based, and 80 percent of the 680 million gallons of U.S.-produced biodiesel was driven by exports to the European Union, until the EU imposed an anti-dumping ban, accusing U.S. firms of selling the fuel below cost.

Earlier this year at a meeting of aviation journalists in Seattle, Richard Wynne, Boeing’s director of environment and aviation policy, acknowledged that developing meaningful aviation biofuel capacity is going to require substantial government investment. “We’re going to have to have some kind of government support, which is why we are working the policy.”

The government announced just that on August 17, when the Department of Energy unveiled a three-year, $510 million matching program to develop commercial aviation and marine biofuels. Funding will come from the Department of Energy, the Agriculture Department and the Navy and will be matched by what the DOE calls “significant” additional investment from the private sector. In the MoU between the Navy and the cabinet departments, the organizations jointly noted the nascent state of the biofuels industry: “Given the current economic environment, significant start-up risks, and competitive barriers posed by firmly established crude oil markets, industry will not assume all of the uncertainty and risk associated with providing a commercially viable production capability for advanced drop-in biofuels. Therefore it is necessary that the federal government cooperates with industry to create a strong demand signal and to make targeted investments to achieve the necessary production capacity required for a robust domestic drop-in biofuels industry.” 

Cotti said the CO2 standard, biofuels and the rest of the “basket” of options on the road to “carbon neutral” aviation industry growth will provide “a lot of choices for people based on their needs.” However, he cautioned that just setting a global CO2 standard is not a magic bullet. “Setting a CO2 standard is no guarantee that a [new] airplane will be sold if the economics aren’t there.”

Will ICAO come up with a CO2 standard that business aviation can live with?

 “I hope so,” Cotti said.