Subject: Emissions

Original: January 15, 2004
Revised:

Policy

General

IBAC supports reasonable and constructive efforts to achieve significant, progressive reductions of aircraft gaseous emissions, consistent with the highest standards of safe and efficient aircraft operations and with the noise certification requirements currently prescribed in Annex 16 Part I. These efforts must also permit continued, unconstrained access to airspace and airports without reducing safety, airport capacity or operational efficiency.

The Kyoto Protocol relates to CO2 only and does not address NOx…. an important distinction, which needs to be borne in mind in the understanding and application of this IBAC policy.

According to the Report of the UN Intergovernmental Panel on Climate Change (IPCC) “Aviation and the Global Atmosphere”:
- of global CO2 man-made emissions, it is estimated that the total civil aviation contribution is of the order of 2% of total emissions, and
- of CO2 emissions attributable to overall civil aviation operations, it is estimated that general aviation contributes only a very small proportion (i.e. of the order of 2%).

Notwithstanding the comparable size of the global business aviation turbine fleet to the airline fleet, the relative performance of business aviation aircraft is such that their typical engine emission products, combined with the significantly lower annual business aircraft utilization (typically, an order of a magnitude less than that for airline aircraft) results in a contribution to CO2 emissions that is extremely low, bordering on insignificant (i.e. of the order of 0.04% of global manmade emissions).
Business aircraft currently in production, and those already in widespread service, have an extremely low impact on the global and local (i.e. airport) environment compared to other ground emitters, or to airline aviation, and thus should not be subject to restrictions on their operations.

Aircraft and Engine Technology

The Intergovernmental Panel on Climate Change (IPCC) projects a 20% improvement in aircraft fuel efficiency, and thus a commensurate reduction in CO2 emissions between 1997 and 2015 for the average of new production aircraft.

NOx reduction technology is progressing faster than the IPCC scenario that estimated a reduction in NOx emissions to levels 30 - 50% below CAEP/2 - developed limits by 2020. These levels may now be realized by 2010 for medium and large turbofan engines (i.e. > 6,000 lbs thrust). Nevertheless, the architecture and design constraints for small engines (i.e.< 6,000 lbs thrust) and turboprops may preclude achieving the ultimate emissions reduction potential on these applications.

Long term targets have been set by the European Community (EC) and the United States National Aeronautics and Space Agency (NASA) for reduction of emissions of CO2 and NOX – out to 2022 – and research work supported by these programmes is making good progress towards demonstrating a technological capability to achieve target levels.

IBAC supports continuing research into technical improvements, however IBAC recognizes that these alone will not be sufficient to compensate for the projected growth in emissions. Despite promising research efforts, concerns still exist about the rate of future progress due to uncertain development funding, the increasing difficulty in transforming NOx reduction technology into products and the diminishing cost-benefit of improving on current technology.

Concerns also exist that emission reductions from advanced aircraft/engine technology currently under development will not be sufficient to counteract the projected growth in aircraft operations. Best practices in airport and airspace operations, aircraft maintenance and operating procedures should be considered the best response.

ICAO Emissions Certification Standards (Annex 16 Volume II)

Applicability

IBAC recommends that ICAO standards for emissions certification continue to be applicable only to medium and high thrust engines, i.e. engines > 6,000 lbs thrust. It is noted that there have been continuous, significant improvements in the emissions performance of low thrust turbofan engines (i. e. engines < 6,000 lbs thrust) and turboprops for more than two decades. Moreover, there are to date no environmental impact studies to justify the imposition of regulations to this class of engines/aircraft.

For medium thrust jet engines (> 6,000 lbs and < 20,000 lbs) and turboprops
IBAC supports retention of the ‘sliding scale’ basis for emissions certification.

NOx

Any new or more stringent NOX certification standard must be technically feasible and economically reasonable for manufacturers and operators i.e. it needs to be based on “proven” technology. It must also achieve a balance between the various gaseous emissions, as well as other factors such as noise reduction, fuel burn and engine reliability.

For engines currently regulated by ICAO, IBAC supports a relatively early date (2008/2012) of applicability for a more stringent standard for NOX emissions certification.*

IBAC opposes a greater increase in stringency related to a later implementation date, which is considered prospective in terms of technology advancement …so -called ‘technology forcing’ standards i.e. standards not based on ‘proven’ technology. This reflects IBAC concern that such standards could detract from the traditional focus on and the priority of airworthiness.

CO2

No need is seen to prescribe standards for the certification of CO2 emissions since these are directly related to fuel burn. Moreover, market place forces are having a positive effect.

Technical / Design Trade-offs

For turbofan engines for which emissions specifications are applicable, the trade-offs between the various emissions and between emissions and noise performance must be taken into account. Any design changes need to be consistent with the highest standards of safe and efficient aircraft operations.

Climb/ Cruise phase

IBAC supports work being undertaken by CAEP relating to cruise/climb emissions certification.

Future Outlook

Any new or more stringent certification standards for emissions to be adopted by ICAO should be applicable for the foreseeable future and should not subsequently be made more stringent unless and until it is technically feasible and economically reasonable to achieve other than marginal improvement.

* Ed note: The definitive IBAC position for CAEP/6 on the percentage increase in NOX stringency and the associated applicability date remains to be established, taking into account the position of ICCAIA.

Market-based Measures

The market-based measures under consideration are:
- emissions charges
- fuel taxes
- emissions trading regimes, and
- voluntary agreements

Emissions Related Charges

It is noted that ICAO considers any levy, which is not cost-based and/or which generates revenue for the account of a General Exchequer is a tax. Long- standing ICAO policy is to urge States to exempt fuel purchased for international flights from taxation. In the context of considering emission-related levies, the ICAO Council, in a Resolution dated 9 December 1996, has expressed a strong preference for the use of charges as opposed to taxes.

Applying the ICAO premise that charges for the air navigation infrastructure are to be cost based, and considering that it is not realistic to determine a cost associated with emissions, IBAC opposes the imposition of emissions -related charges.

Before emissions charges are considered, a revenue disbursement methodology must be established. If such charges are nevertheless introduced, they must be revenue neutral and used to mitigate aircraft environmental impact.

Regarding the applicability of emissions related charges, it is noted that differences exist between the definition of “International Operations” as adopted by the UN Framework Convention on Climate Control (FCCC) and the ICAO definition which IBAC supports. It is noted that, per the ICAO definition, all operations among European States are deemed international.

Only one set of reference data for emissions certification is needed by the industry for any emission-related charge. Any such charge should be calculated based on the emissions quantity, evaluated in a fair and economically reasonable manner.

Voluntary Agreements

Whilst voluntary agreements may have relevance to operators with significant fleet sizes, such agreements would rarely be relevant in the context of business aviation because, amongst other reasons the provision of transportation, notably air transportation, is typically not the main or primary business of the operators of business aircraft.

Open Emissions Trading

IBAC recognizes that this is the most cost-effective market-based measure.

There are significant challenges to implementing any emissions trading regime. Business aviation is a de minimus source of aviation emissions. Therefore the establishment and operation of an emissions trading regime for business aviation may not be a worthwhile endeavor.

The implications of the possible co-existence of several or more market based regimes for reducing emissions requires consideration. There is a prospect that regimes applicable to domestic operations will be adopted by some States. Whether such regimes can harmoniously co-exist with those adopted for international operations will need to be clarified.

Regional / National / Local restrictions

IBAC strongly urges that States uphold the application of ICAO standards and refrain from the adoption of rules unique to a State or local jurisdiction.

Any consideration of access restrictions applicable to an airport or airspace must be justified on the basis of valid environmental, social and economic impact studies.

CNS/ATM Implementation - Impact and Contribution

IBAC acknowledges that CNS/ATM implementation will assist in the reduction of emissions.

Improvement of ATM can contribute to reduction in flight time and/or fuel burn, and thus reduce emissions. The United Nations Intergovernmental Panel for Climate Change (IPCC) Special Report on Aviation and the Global Atmosphere (1999) states that the ICAO CNS/ATM Systems Concept, once fully implemented on a worldwide basis, has the potential to further improve overall fuel efficiency by 6 -12% - representing an annual reduction of approximately 20 million tonnes of CO2 emissions.

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Source of Policy: (1) Original, Governing Board, mail vote 15 January 2004