Global Aviation Dialogues: crucial elements omitted from latest MBM draft proposal

The International Civil Aviation Organization (ICAO) organized five Global Aviation Dialogues (GLADs) around the world to discuss the latest draft proposal on a market based measure to curb emissions from international aviation. The dialogues came to a close on 8 April, but there are already worrying signs that important elements around ambition, emission unit quality criteria and double counting of these units may not be adequately addressed. If left untreated, these missing elements would lead to a toothless proposal that will do little for the environment.

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Ambition action points

The most glaring omission in the text is a binding goal. Paragraph 2 still references an “aspiration goal” of stabilizing emissions at 2020 levels through in-sector reductions and offsetting (the carbon neutral growth 2020 goal, or CNG2020). Compared to efforts being made in other sectors, this goal should be a feasible and mandatory starting point for the aviation industry.

For this goal to be achieved, 100% of emissions above 2020 levels should be covered. In the current draft of the proposal, some states are exempted and their emissions are not reallocated to others. This gap could be enormous, as in the current proposal countries like China, India, Argentina, Mexico and South Africa would be exempt for the first 5 years, leaving a shortfall of emissions that need to be covered so that carbon neutral growth starts in 2020 and not 2025.

Finally, an essential part of the deal is realizing that the goal of CNG2020 is not ambitious enough to keep the sector on a path consistent with 2 degrees let alone 1.5 degrees. In light of the Paris Agreement, the long-term contribution of aviation should be rapidly and substantially increased over time, meaning the proposal must reference a review for more ambition every three years.

All or nothing for Emission Unit Criteria?

There are promising discussions going on at the technical level to develop robust emissions criteria that can inform airlines in their offset purchases. In the draft proposal this work is being referred to as “guidance”, meaning “not binding”.

Cost-effectiveness is a priority for airlines buying offsets. If the quality criteria does not need to be respected then airlines will largely purchase the least-expensive, which are generally the most environmentally and socially dubious credits in the most unregulated markets. Making the criteria common to all and binding as well as establishing a negative list of ineligible credit types, being developed in later technical discussions, are ways that the Assembly Resolution can increase the integrity of the GMBM.

Double Counting déjà vu

The UNFCCC has already committed to developing a transparency framework under the Paris Agreement to ensure proper accounting of INDCs that addresses “the need to ensure that double counting is avoided”. ICAO needs to reflect these values for emission unit registries under paragraph 17 of the draft proposal as double counting of emissions units will be a growing problem in a world where all countries, and all airline operators, have emissions targets. For every emission reduction, only one group can be credited and this needs to be respected in both ICAO and the UNFCCC. The ICAO rules would work best and most effectively if harmonized with those being developed under the UNFCCC.

All the aspects mentioned above are minimum rules needed to ensure a GMBM with environmental integrity. It seems a proper environmental discussion has yet to take off…

by Kelsey Perlman