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Next week/tomorrow MEPs on the Parliament’s environment committee will hold a hearing on the Commission’s approach to this scheme. There’s a lot to critique. To start with, aiming to offset only emissions above 2020 levels is a pretty weak target, certainly well short of what the Paris agreement requires. And because participation in CORSIA is voluntary, the scheme will fall short of this 2020 target. Offsets are so cheap and the target is so weak that the resulting cost will also do nothing to incentivise greater efficiencies from within the aviation sector. And the measure will not address aviation’s considerable non-CO2 climate impacts, which equal or even exceed the CO2 impacts.
But the biggest problem lies at the heart at the measure: its reliance on offsetting. All that the states agreed to in 2016 was that there should be an offsetting mechanism, but setting the rules on what counts as genuine offsetting was left to later. And that’s essential, as we know from decades of experience that offsetting can go badly wrong, with promised emission reductions from offsetting projects amounting to nothing more than scraps of paper.
It’s been left to ICAO’s council to develop the necessary rules. The process is now nearing completion, with the council set to adopt a final version in June this year. However, what we know so far does not give us much hope that what emerges from this process will deliver real environmental benefits. There are at least three ways that CORSIA can fall short.
The first relates to enforcing the measure. Any mechanism like this needs to have strong enforcement procedures to ensure that all airlines and states are abiding by the rules both to ensure environmental integrity and a commercial level playing field. However ICAO, as an international body, lacks the sort of judicial enforcement mechanism that exists for other carbon markets. For example, other carbon markets have enforcement authorities who can bring non-compliant operators in front of a judge. As a substitute, the ICAO rules should require a high degree of transparency: by requiring airlines to publicly disclose what their total emissions are and what offsets they have purchased. This is fairly standard for most carbon markets, but the rules as currently drafted leave plenty of loopholes.
The second relates to the type of offsets that airlines are permitted to buy to qualify under the scheme. We know that global carbon markets are full of dodgy offsets. One study found that one supply of offsets, from the UN’s Clean Development Mechanism, had only a 7% chance of delivering real emission reductions. If we want CORSIA to work, we’ll need to ensure the safeguards are put in place so that only effective offsets are permitted. While the rules as drafted contain some important principles, we’ve yet to find out how they’ll be enforced. The danger is that some states may go their own way and allow their airlines to buy cheaper and lower quality offsets.
Finally, there are serious questions about the use of alternative fuels in this mechanism. Airlines will be allowed to count the use of such fuels against any offsetting obligation. So the sustainability rules for alternative fuels need to be as tight as they are for offsets. However last November, when approving a draft of these rules, ICAO’s council rejected 10 of the 12 sustainability criteria for alternative fuels that a technical group comprised of national, industry and civil society experts has spent several years developing. The door is now open for airlines to use alternative fuels which have negative impacts on labour rights or which will deliver no environmental benefits and may even do harm.
This last decision by ICAO’s council is especially worrying. It shows that this body, which operates largely in secret, is prepared to water down environmental rules when it faces pressure from states or industry. In the years to come, ICAO’s council will have a number of other big decisions to make, mostly importantly what type of offset programmes will be eligible for use under CORSIA. That the council is backtracking from the advice of its own experts well before the scheme has even started is not a harbinger of environmental integrity.
The draft rules (called SARPS) have now gone to all 193 ICAO member states, with a deadline of 5 March for them to respond. It is important that states let ICAO’s council know that when they agreed to an offsetting mechanism in 2016, it was their intention that the mechanism would be properly enforced, and have high environmental integrity. It’s clear that the general public now needs to put pressure on their states to deliver such a message.
You’ll find a draft of these SARPs here, along with our suggestions on what improvements need to be made if the measure is to have any chance of succeeding.
But as we said at the top, even a fully functioning CORSIA won’t deliver the sort of emission reductions that are needed from the aviation sector for the Paris agreement – that is steep cuts in emissions and then zero emissions by later in this century. With ICAO’s council offering no guarantee that it can implement or enforce an effective mechanism, we’d be wise not to put all our eggs in that basket. That’s why, along with working to make CORSIA function as well as it can, T&E is putting its efforts into more effective regional and national policies such as carbon floor pricing, phasing out fossil fuel subsidies, blocking airport expansion and supporting alternative fuels which won't compete with food.
Aviation’s climate impact won’t be solved overnight, and it won’t be solved by one actor. What’s needed is effective global measures matched with the greater regional and national ambition that the Paris agreement was designed to deliver.