ATA Supports Initiatives and Policies To Help Reduce Greenhouse Gases at a Global Level

Commercial aviation helps drive more than 10M American jobs and 5 cents of every dollar of U.S. GDP
Commercial aviation drives more than $1 trillion per year in economic activity
In 2012, U.S. airlines moved more than 48,000 tons of cargo per day
In 2012, the value of a kilogram of U.S. merchandise exported by air averaged 121 times the value exported by sea
For every 100 airline jobs, some 360 are supported outside of the airline industry
Federal taxes constitute $61 – or 20% – of the price of a typical $300 domestic round-trip ticket
In 2011, U.S. airlines carried 16 percent more passengers and cargo using 10 percent less fuel than in 2000
Domestically, airlines drive 5% of economic activity but account for 2% of man-made GHG emissions
From 2000-2011, airlines reduced GHG emissions by 11% while transporting 16% more passengers and cargo
From 1975-2011, U.S. airlines and their partners reduced significant noise exposure by 99%
Commercial air travel is the safest form of intercity transportation in the United States
In the most recent decade, scheduled air service on U.S. airlines was seven times safer than in the 1970s
From 2000-2012, U.S. airlines improved the on-time arrival rate from 72.6% to 81.9%
From 2000-2012, U.S. airlines reduced the flight cancellation rate sharply from 3.30% to 1.29%
Airfares are a bargain: From 2000-2012, U.S. CPI rose 33% while average domestic fare rose just 13%
Adjusted for inflation, the average round-trip domestic airfare fell 15% from 2000
2007 domestic flight delays cost the United States approximately $31 billion
In 2012, the value of U.S. merchandise exported by air reached an all-time high of $427B
In 2012, U.S. exports of air-travel services reached an all-time high of $39.5B, driving a $5.1B trade surplus
In 2012, U.S. passenger and cargo airlines spent more than $50B on fuel, averaging 36% of operating expenses
In 2012, U.S. airlines posted the lowest annual rate of mishandled baggage ever recorded
FAA projects U.S. air travel demand to top 1 billion passengers in 2027
In 2012, US airlines flew 83.4 million passengers in scheduled international service - a record high
In 2012, the total value of merchandise exported from or imported to the United States by air exceeded $927 billion
In 2012, 7.15 teragrams of merchandise was exported from or imported to the United States by air

	ATA Supports Initiatives and Policies To Help Reduce Greenhouse Gases at a Global Level
	PubZone1 May 18, 2011 Kierán Suckling Executive Director, Center for Biological Diversity ksuckling@biologicaldiversity.org Trip Van Noppen President, Earthjustice tvannoppen@earthjustice.org Margie Alt Executive Director, Environment America margie@environmentamerica.org Fred Krupp President, Environmental Defense Fund c/o llee@edf.org Frances Beinecke President, Natural Resources Defense Council fbeinecke@nrdc.org Michael Brune Executive Director, Sierra Club Michael.brune@sierraclub.org Re: May 11 Airline Letters and Web Postings Ladies and Gentlemen: It was with surprise and disappointment that we read your May 11 letters and web postings criticizing various members of the Air Transport Association of America (ATA) in light of their participation with ATA in our challenge against application of the European Emissions Trading Scheme (EU ETS) to U.S. airlines. We want to ensure you are aware of the facts, as much of what you have said has misstated them, whether intentionally or not. The premise of your criticism is that we should be considered “anti-environment” because we have challenged the legality of a method of regulating greenhouse gas emissions. In fact, however, ATA and its members are part of a broad group of the aviation industry that is seeking to address aircraft greenhouse gas emissions at a global level, through legal measures rather than through a patchwork of differing measures of dubious legality. The truth of the matter, as the facts demonstrate, is that ATA and its members support technology, infrastructure and operating initiatives and policies that will further reduce the airline industry’s already low-levels of greenhouse gas emissions. The airline industry’s plan will achieve zero emissions growth and, ultimately, real reductions in emissions, without resorting to an uneconomic emissions trading scheme unilaterally imposed in violation of well-recognized international law. Fact #1: The U.S. airlines have a strong record of fuel efficiency improvements and greenhouse gas emissions (GHG) savings. The commercial airlines represent only 2 percent of the nation’s man-made carbon dioxide (CO₂) inventory. Even so, by improving their fuel efficiency by 110 percent between 1978 and 2009, the U.S. airlines saved over 2.9 billion metric tonnes of CO₂– roughly equivalent to taking 19 million cars off the road each of those years.1 We accomplished this through significant investments in new aircraft, advanced avionics and innovations in operations. In fact, the U.S. Environmental Protection Agency (EPA) confirms that U.S. airline CO₂ emissions in 2008 were 13 percent below 1990 levels, while emissions from U.S. automobiles, trains and trucks increased respectively by 19, 30 and 74 percent over that time period.^² Your letters and postings reflect either a misunderstanding on your part or an effort to misrepresent the data showing the airlines’ real record. The airlines’ record, which has been achieved without punitive regulation like the EU ETS, should be praised by organizations such as yours that call for emissions savings. Fact #2: The U.S. airlines have committed to an aggressive program to reduce their CO₂ emissions even further. As you undoubtedly know – because we have met with many of your groups personally – in 2009 the U.S. airlines, joined by the worldwide airlines represented by the International Air Transport Association (IATA), proposed a “global sectoral approach” to aviation GHG emissions, including an aggressive set of measures and emissions targets. Under this approach, the framework for both international and domestic aviation emissions would be established internationally. All airline emissions would be subject to emissions targets requiring industry and governments to do their part. As proposed by the industry, these would be an annual average fuel efficiency improvement of 1.5 percent through 2020 and carbon-neutral growth from 2020, with an aspirational goal of a 50 percent reduction in CO₂ by 2050 relative to 2005 levels. While the airlines will have to make significant investments to meet these targets, they also depend on governments investing in their areas of responsibility, including air traffic control modernization and research and development to advance shared priorities such as sustainable alternative fuels.^³ Significantly, at its 2010 Assembly, the International Civil Aviation Organization (ICAO), the United Nations body with authority for setting standards for international aviation, adopted much of the industry’s framework. Accordingly, while climate talks have stalled in the United Nations Framework Convention on Climate Change (UNFCCC) process, the airlines are moving forward with real CO₂emissions measures, as is the United Nations body that is charged with addressing aviation GHG emissions. Again, the facts show that the airline industry’s initiatives should be a basis for praise. Fact #3: The U.S. airlines are complying with the EU ETS even as we challenge its application to our airlines in court. Your letters and postings misrepresent the truth, implying that the U.S. airlines are not complying with the EU ETS. In fact, although we challenge the legality of the scheme as applied to U.S. airlines – and the underlying policy approach as well – our member airlines have been complying with the ETS, under protest, since the emissions plan requirements came into effect in 2009 and through the reporting and other requirements applying today. This effort has required the airlines to expend a significant amount of resources to ensure compliance with EU-specific fuel and emissions plan monitoring and reporting requirements, even though the U.S. airlines have for many years been reporting detailed fuel data to the U.S. government covering all U.S. airline operations that provide the basis for the best airline CO₂ dataset in the world. All the while complying, ATA and its member airlines have raised very real questions of law and policy about the EU ETS, and we are doing so in the appropriate forum, the very courts of law that your groups so often avail themselves of when you have legal concerns, including situations where you have disputed a particular regulatory avenue. Unilaterally applying the EU ETS to non-EU airlines violates several provisions in the Convention on International Civil Aviation (commonly referred to as the “Chicago Convention”),^⁴ customary international law and the Kyoto Protocol. One must also question the effectiveness of a scheme that the EU officials themselves decided had to be shut down for some time due to admitted fraud and thievery. Perhaps more importantly, the scheme as applied to aviation is counterproductive to reducing airline emissions. It imposes a steep tax on airlines, siphoning away the very funds that our airlines need to continue investing in the technological, operational and infrastructure improvements required to meet our emissions targets. We are surprised that you so whole-heartedly support this unlawful scheme in light of questions involving its implementation and considering that none of the monies collected by the European States under the scheme are targeted to go to environmental purposes (and, in fact, the United Kingdom has denounced any requirement to do so). Instead, you should recognize that our global sectoral approach and our proven track record of CO₂ emissions savings offer better environmental protection. Fact #4: ATA and its airlines continue to work to reduce the environmental footprint of our operations. For example, even though we reduced the number of people in the U.S. affected by aircraft noise by 94 percent between 1975 and today, while increasing passenger air traffic by almost four times, we continue to introduce new measures to further reduce aircraft noise exposures. With specific respect to aviation GHG emissions, we are leading the charge for more environmentally friendly, commercially viable alternative fuels. In fact, we co-founded the Commercial Aviation Alternative Fuels Initiative® (CAAFI) to accomplish the sustainable development and deployment of such fuels and welcomed environmental groups – including some of you to whom this letter is addressed – to our August 2010 CAAFI Environment Team meeting to share with us your expertise in this area. Additionally, our member airlines have flown critical demonstration flights to help with the certification of alternative fuels and have executed agreements with alternative fuel producers to advance the technologies and production. Indeed, ATA and our members have worked with the U.S. federal government to make sustainable aviation alternative fuels a priority and are working together across the public and private sectors to turn this important opportunity for further environmental protection and energy independence into reality. We are committed to press on with such meaningful initiatives. * * * * * * * In light of the above, we urge you to correct the misstatements you have made. We also would welcome a meeting with you to discuss these important issues. Sincerely yours, Nancy N. Young Vice President, Environmental Affairs [1] Fuel savings source: U.S. DOT Form 41; automobile equivalent calculations from www.epa.gov/cleanenergy/energy-resources/calculator.html. [2] Source: U.S. EPA, Inventory of U.S. Greenhouse Gas Emissions & Sinks, 1990-2008, Table 2-5. [3] The Natural Research Defense Council has expressly recognized the importance of the government’s contribution in these areas. See Testimony of Deron Lovaas, Natural Resources Defense Council, House Select Committee on Energy Independence and Global Warming (April 2008). [4] Perhaps most significantly, that treaty (in Article 1) states that countries have sovereignty over the airlines in their own airspace. And yet, by its terms, the EU ETS provisions regulate U.S. airlines in U.S. airspace. For example, for a flight of a U.S. carrier from Dallas to London, the proposed legislation would regulate the emissions from that flight on the ground and as it takes off in Dallas, as it flies over Texas, Oklahoma, Missouri, Illinois, Indiana and Michigan, within U.S. offshore territory, over Canada and the Atlantic Ocean. Thus, the EU ETS provisions would regulate the entire flight, even though the flight would be in EU airspace for only a tiny fraction of the journey. PubZone2	A4A advocates measures to support aviation safety, security and well-being.