Could ICAO’s CO2 Standard Not Actually Cover Any Aircraft? Yes, If Nobody’s Watching
As our series of rankings show, in the four years 2010-2013 the gap between the most and least fuel-efficient airlines on U.S. domestic operations has not closed at all. Furthermore, under business-as-usual scenarios aviation carbon dioxide (CO2) emissions are predicted to triple by midcentury. It is obvious, then, that fuel prices and market forces alone are not sufficient to put aviation CO2 emissions under control.
The International Civil Aviation Organization (ICAO), a UN agency for civil aviation, is working to develop two policies to address aviation emissions by 2016: a global market-based measure to put a price on carbon, and a CO2 emissions (efficiency) standard for new airplanes. If ICAO fails to deliver either policy, regional policies will take precedence in Europe (EU ETS) and the US (standards under the Clean Air Act). In any event, ICAO can make recommendations for standards, but member states must enforce them, as the US EPA is planning to do.
Global or regional, it is important that a CO2 standard actually reduce emissions. One of the hot debate topics in ICAO is whether the standard will be applied to all aircraft rolled out of a factory, or only to new designs certified after the expected application date of January 1, 2020. (In-service aircraft, those already flying before the date the standard takes effect, will not be affected by this new regulation). In other words, a new aircraft may or may not be covered by the regulation, depending on which one of these coverage options is chosen:
- New types only (NT). Only airplanes for which a type-certification standard is applied for after January 1, 2020 would be regulated. Given the three to five years it takes for an aircraft today to be type certified, this would translate to an entry-into-service date of approximately 2024. Most of the “future” airplanes that are already announced (B777X, A330neo, etc) will acquire their type certificates well before 2024 and would therefore be grandfathered into the standard in perpetuity even if they are manufactured and delivered after the standard takes effect.
- All new in-production (InP). All aircraft that are rolled out of the manufacturing plant after a given date would be regulated under the standard. This option would be consistent with how efficiency standards have been applied to all other modes (passenger vehicles, heavy duty vehicles, etc). Furthermore, it would avoid potentially perverse incentives whereby manufacturers might manipulate the release date of a new type in order to evade regulation.
One way to assess the expected benefits of each approach is to compare their coverage of future fleets. Since a new-type-only standard would grandfather in essentially all of today’s current and announced aircraft types, we would expect it to take much more time to cover the in-service fleet than a standard affecting all new in-production aircraft. To compare the magnitude of coverage between “new types only” and “all new in production” applicability of the standard, we used Ascend delivery projection combined with ICAO’s fleet projection to predict how many airplanes would be covered in the first decade of the implementation of the standard under each option. The results are presented in the chart below.
The chart represents standard coverage under “new types only” and “all new in-production” options. It shows that only about 5% of the 2030 global fleet would be regulated under “new types” option, while 95% would be unaffected. This limited coverage suggests a minimal impact on global CO2 emissions from aircraft, regardless of the standard’s stringency level. However, the CO2 standard would have a much larger potential impact if applied to all new in-production airplanes. The chart also illustrates that 55% of the global fleet would be regulated in 2030 under that option, more than a tenfold increase.
Coverage of the CO2 Standard under “New Type Only” and “All New In-Production” Options
ICAO has been working on the standard since 2009, and has yet to adopt a single enforceable measure to reduce CO2 from aircraft in the 17 years since it was charged with developing a climate policy for international aviation as part of the Kyoto Protocol discussions. Time is running out, and ICAO needs to wrap its work up soon. Let’s hope that they make the right decisions and make sure that this very anticipated standard will actually make a difference.