When it comes to climate change, should we leave the FAA on auto-pilot?

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The Federal Aviation Administration (FAA) is facing changes this month as new leadership is installed and as Congress provides it with new legislative authorization and direction. Will these changes lead to a shift in direction away from resistance and obfuscation on the challenge of climate change?

This posting has been prepared by the Climate Science Watch research team. See previous CSW posts of July 18 and July 29 and our report, NextGen Air Transportation System Progress Reports Ignore Climate Change.

September is an eventful month for the US airline industry and the Federal Aviation Administration.  Many changes are in the wind.  FAA’s pilot, Administrator Marion Blakey, stepped down at the end of her five-year term this past Friday, September 14, leaving Acting FAA Administrator Robert Sturgell in charge. Blakey’s replacement announcement is imminent.  On September 17, Secretary of Transportation Mary Peters named Hank Krawkoski to be FAA’s co-pilot; he leaves his position as United Airlines vice president of flight operations to become FAA’s chief operating officer, a post that has been vacant since March.  This new leadership in the cockpit of the FAA will have much to mull over as Congress is now in the process of passing major FAA reauthorization bills.  When the ink is dry they will have added several new flight plans for the agency. 

As the US airline industry faces a host of challenges—steep international competition, rapidly increasing consumer demand, flight delays and congestion, the ever-pressing need for safety, controversy over federal vs. private insurance against terrorist acts, and so on— climate change looms as a sleeping giant.  As we have noted, one of the Achilles heels for the US aviation industry could be the complex mixture of greenhouse gases and precursors—carbon dioxide, water vapor, and oxides of nitrogen—injected directly into the atmosphere by every jet and turboprop in the sky. 

As both the House and the Senate grapple with proposed carbon-cutting measures — carbon taxes and “cap-and-trade” schemes for big CO2 emitters such as coal-fired power plants; increased Corporate Average Fuel Economy (CAFE ) standards for cars, SUVs, and trucks; and mandatory set-asides for clean renewable energy in the mix of energy generation options — emissions from aircraft seem, at least for the time being, to have gone over the heads of most policymakers engaged in the rush to cut carbon emissions.  This, despite the fact that the European Union is threatening to penalize US and other foreign aircraft if they emit CO2 in Europe’s airspace, another harbinger of future pressure expected to be placed on the carbon-intensive US by the international community to reduce its per capita greenhouse gas emissions. 

Rep. Ed Markey, Chairman of the House Select Committee on Energy Independence and Global Warming, has taken notice of FAA’s recalcitrance to address emissions from aircraft honestly and directly (in part due to his notice of the CSW July report), and has sent a letter [PDF] to the FAA Administrator requesting responses to four specific questions.  However, the September 4 deadline for responding has come and gone, and our understanding is that the FAA will not yet commit to a new deadline to respond. 

Given the actions, inactions, and statements made by high-level officials, one might conclude that the FAA is asleep at the wheel when it comes to climate change.  On the contrary, it appears that climate change is fully visible on the FAA radar screen, as evidenced by a variety of tactical maneuvers that any reasonable observer could interpret as intended to keep policymakers from focusing on aircraft emissions, even as the stakes against global ecological health and well-being continue to climb. 

Carl Burleson is the Director of the Federal Aviation Administration’s Office of Environment and Energy, and head of the JPDO Environment Working Group.  He appears to be the gatekeeper within FAA for matters relating to the environmental impacts of the US avaition industry. While claiming to be concerned about the environment, Burleson has stymied efforts even suggestive of requiring the US aviation industry to meet targets and timetables for greenhouse gas (GHG) emissions reductions.  Moreover, he has issued misleading statements about the industry’s track record on GHG emissions trends. 

From a June 2006 article in the International Herald Tribune describing the environmental issues facing the aviation industry and how they vary from region to region:

“Noise is the No. 1 issue in the United States,” said Carl Burleson, the U.S. Federal Aviation Administration’s environmental director. “Greenhouse gas is a European issue, not a U.S. issue.”

That the European Union differs with his position is well documented: the EU has proposed in its Emissions Trading Scheme (ETS) to require foreign airlines flying over or into European airspace to either curb or pay for their greenhouse gas emissions.  This notion is now being vetted through the International Civil Aviation Organization’s (ICAO) Committee on Aviation and Environment Protection (CAEP), which met this month to consider this proposal and other pressing environmental issues in global aviation.  The US, through the FAA, has reportedly threatened to retaliate with trade sanctions or other legal tools if the EU attempts this.

Burleson is recently reported to have said that, while he “not opposed to emissions trading, per se,” he “credits the US government for inventing the cap-and-trade concept as an environmental policy” but “in areas other than aviation.”  He also asserts that the US approach for reducing carbon emissions may be different from the EU’s because the US “aviation systems have widely varying traffic patterns.”  Whatever that means.

There are several additional examples of smoke-blowing launched from the FAA’s Office of Environment and Energy. 

Burleson’s claims about emissions trends

In an August 15 article In These Times online, Burleson is quoted as criticizing our report on NextGen, aviation, and climate change (which he refers to as “Piltz’s study”) for being “factually inaccurate.”  The article says Burleson claimed that, “despite Piltz’s claims that greenhouse gas emissions from planes have been increasing, Bureau of Transportation statistics show CO2 emissions from jet fuel have actually decreased by 5 percent since 2000, despite a growth in capacity.”

A similar assertion is made in a recently posted “fact sheet” on FAA’s official website titled “Getting the Green Light for Aviation:  How FAA Initiatives Are Reducing Environmental Impacts.” Among claims that the US airline industry is moving more people more efficiently and much more quietly than in decades past, it also claims that the “US commercial aviation industry has improved its energy efficiency, moving twelve percent more people and twenty-two percent more freight than it did in 2000, while burning five percent less fuel and producing 10 million tons less carbon dioxide.” 

The “Plane Truth” about US aviation industry emissions trends

While the statements regarding the difference in emissions between 2000 and 2005 are technically true, they represent the type of misleading statement that results from cherry-picking data and omitting explanations.  A flashback of the events surrounding September 11, 2001, throws a splash of cold water on Burleson’s argument.  Fortunately, we can still gain access to sector-by-sector, industry-by-industry annual emissions data collected and reported by the US Environmental Protection Agency (which is the Bureau of Transportation Statistics’ source of information on this topic). 

The annual listings of CO2 emissions for each year beginning in 1990 and ending in 2005 (data for 2006 will be forthcoming later this year) reveal that, indeed, CO2 emissions from US commercial domestic flights for the year 2005 were less than those for the year 2000.  However, what Burleson fails to mention is the heavy hit the US commercial airline industry withstood after the attacks of September 11, when Americans abruptly and in large numbers opted to stop flying and use ground transportation to get where they needed to go — in the fourth quarter of 2001, throughout of much of 2002, and to a lesser extent in following years.
According to the US EPA’s Inventory of US Greenhouse Gas Emissions and Sinks: 1990-2005 (here) and associated EPA databases, CO2 emissions from US commercial, domestic flights (defined as flights that take off and land within the continental US) experienced steady increases from approximately 170 teragrams (Tg, or million metric tons)  in the early 1990s to a peak of 196 Tg in 2000 (a 15.5% increase in less than a decade). Emissions then dropped sharply, reaching 178 Tg in 2002, and 175 Tg in 2003, an 11% decrease from 2000 to 2003.  The drop can be attributed to a complex set of factors that includes a drop in volume due to the 9/11 attacks but also to gains in efficiency per mile traveled and other factors. 

Even with these efficiency gains, however, as the comfort level with flying returned and more Americans took to the skies, there was a steady and rapid incline in CO2 emissions to 179 Tg in 2004, jumping to 186 Tg in 2005, a 6.5% increase in just two years.  EPA emissions data for 2006 will become available in the latter part of October; all indications are that the upward trend will continue. 

Though this was not explicit in the fact sheet, FAA’s claim of a 10 million ton reduction in carbon dioxide over a five year period refers exclusively to commercial domestic flights, as evidenced by the data cited:  196 Tg in 2000 down approximately 10 million metric tons to 186 Tg in 2005.  What is not mentioned is the 37% increase in emissions from US commercial international flights (defined as those which take off from US soil and land in another country), from 46 Tg in 1990 to 63 Tg in 2005. 
Thus, overall CO2 emissions from commercial domestic and international (non-military) flights combined have risen over the fifteen-year time period for which we have good data, from 226 Tg in 1990 to 249 Tg in 2005, a 10.2 % increase. 

Curiously, total CO2 emissions from all US military air traffic are reported by EPA to have decreased substantially over the past fifteen years, from 48 Tg in 1990 to 28 Tg in 2005, a 42% drop.  It is not clear to us what might account for this.

The data are summarized in the following table prepared by CSW:
Carbon_Dioxide_Emissions_from_US_Aircraft_1990-2005.xls

Since the amount of CO2 emitted per unit of fuel burned is assumed to remain constant, reducing CO2 emissions means doing one of three basic things:  reducing fuel combustion per distance traveled, reducing the total distance traveled per unit of time, or switching to a type of fuel that does not emit as much CO2.  Globally, on average, aircraft are getting more efficient.  It is unclear how much more efficient the current fleet can become.  Reducing the number of miles traveled in a year almost by definition would mean fewer flights.  Fuel switching has some promise, but we are not holding our breath; many technological obstacles remain to be overcome.  The FAA reports in its fact sheet that, “In partnership with airlines, airports, and manufacturers, FAA has launched CAAFI, the Commercial Aviation Alternative Fuels Initiative. CAAFI is leading efforts to develop alternative fuels to ensure an affordable and stable supply of environmentally progressive aviation fuels.”

The FAA is taking some positive steps that could begin to tackle the problem of emissions.  The most visible example is FAA’s recent proposal to Congress to create the Continuous Low Emissions, Energy and Noise (CLEEN) program to develop and foster industry acceptance of new technologies that reduce environmental impacts.  This proposal will almost certainly make its way into the FAA reauthorization bills being acted upon this week in Congress.  Also proposed is a permanent Airport Cooperative Research Program, with added funding for airport environmental concerns as well as a demonstration program to accelerate use of procedures and practices to reduce noise and emissions.  This provision may also be adopted by Congress.  In addition, the FAA reports that it has entered into agreements with the European Union to cooperate through the Atlantic Interoperability Initiative to Reduce Emissions (AIRE) to accelerate the development and use of environmentally friendly procedures to reduce emissions and noise.

These appear to be well-intentioned initiatives.  However, they do not place any constraint on the growth of total greenhouse-gas emissions from aviation. The initiatives still allow for a major expansion of U.S. aviation being planned under NextGen (the Next Generation Air Transportation System) without any accompanying requirement for curtailing emissions.

In 2005 carbon dioxide emissions from U.S. comercial aviation accounted for 3.4 percent of total U.S. greenhouse gas emissions (according to the US EPA’s Inventory of US Greenhouse Gas Emissions and Sinks: 1990-2005 and associated EPA databases). As we noted in our report, aviation’s percentage of the total is likely to increase as other sectors become less carbon-intensive — especially given the aggressive plans for expanding the aviation industry — a doubling or perhaps even a tripling by 2025. As the major greenhouse gas-emitting sectors, including electric power, ground transportation, and buildings are brought under the carbon-cutting umbrella at the federal policymaking level, we believe the aviation sector should not be given an automatic pass. The FAA and the aviation industry should be included squarely and honestly in global warming mitigation policymaking. 

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