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 14%
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

Coalition of Aviation Stakeholders Encourages the President to Challenge the EU ETS By Initiating an Article 84 Proceeding

September 17, 2012

The Honorable Barack H. Obama
President of the United States
The White House
1600 Pennsylvania Avenue
Washington, D.C. 20500

Dear Mr. President:

The undersigned coalition of aviation stakeholders strongly encourages you to challenge the inclusion of international aviation under the European Union Emissions Trading Scheme (EU ETS) by initiating an Article 84 proceeding in the International Civil Aviation Organization (ICAO). Standing up against the application of this unilateral scheme on U.S. airlines and general aviation aircraft operators is necessary to protect U.S. sovereignty and jobs. And it is the right position for the environment, since it will foster implementation of a truly international approach to aviation greenhouse gas emissions that will produce a better environmental outcome than a unilateral scheme. In fact, draining away any funds through taxation or cap-and-trade schemes to general government funds reduces the ability of our industry to limit emissions.

If this EU breach of U.S. sovereignty - the imposition of an EU tax on U.S. airlines, aircraft operators and citizens while on the ground in the United States, over our airspace and international waters - goes unanswered, it almost certainly will result in other such schemes affecting a variety of sectors of the U.S. economy. In addition, the EU ETS will likely lead to job losses in the aviation, manufacturing and travel industries, which is undesirable under any circumstances, but especially in this time of economic uncertainty.

The aviation sector has a tremendous fuel efficiency and emissions-savings record. We have achieved this by investing hundreds of billions of dollars in new aircraft, new engines and new equipment. Because fuel costs represent about 40 percent of our operating costs, we are already highly incentivized to reduce our fuel consumption and emissions. That’s why our industry represents just 2 percent of all greenhouse gas emissions in the United States while driving 5 percent of the nation’s GDP. And we are not stopping there. U.S. airlines have committed billions of dollars toward the purchase of more efficient aircraft like the Boeing 787 Dreamliner and 737 MAX. Mr. President, this is how we reduce emissions, improve our efficiency and create good American manufacturing jobs.

The United States must answer, and an Article 84 action is an appropriate and critical part of that answer. An Article 84 proceeding under the Chicago Convention is the dispute mechanism to which all 191 ICAO Member States have agreed by treaty. Further, contrary to what some have asserted, the private legal action heard by the European Court of Justice ECJ did not resolve the legal questions that would arise in an Article 84 case. In fact, the ECJ refused to hear questions posed under the Chicago Convention and determined that the private parties in that action did not have standing to bring sovereignty claims. Moreover, an Article 84 action will prompt, rather than impede, agreement and implementation of a global framework for addressing aviation greenhouse gas emissions.

Our organizations continue to support the global framework for addressing aviation greenhouse gas emissions as agreed at the 2010 ICAO Assembly. Work is going on now to further flesh out that agreement and to put it into operation. However, the EU ETS has been a roadblock to reaching full agreement and it must be removed.

ICAO has a proven track record of efficiently handling an Article 84 dispute while simultaneously advancing new environmental standards. Indeed, when the United States brought an Article 84 challenge to the illegal EU ban of aircraft fitted with noise “hushkit” technology in 2000, ICAO also was working on a new noise standard for aircraft and on a new international framework for addressing community noise exposure in the vicinity of airports. It was during the time the Article 84 proceeding was pending before ICAO that the EU first stayed and then withdrew its wrongful hushkit ban. The ICAO States not only advanced but unanimously adopted the Chapter 4 noise standard and a global framework for aircraft noise management, known as the “Balanced Approach to Noise”. With ICAO currently working on a carbon dioxide standard for aircraft as a means of implementing the global approach to aviation and climate change, the parallels to today’s dispute regarding the EU ETS are clear.

While the global emissions reduction program is being further developed, we are continuing to invest billions of dollars in new aircraft and engines, support the deployment of technology and procedures for the “Next Generation“ (NextGen) air traffic management system and utilize the creativity of our employees to make operations more efficient without sacrificing safety. Working closely with the Department of Defense, we also are driving toward the deployment of sustainable alternative aviation fuels, which will not only bring additional emissions savings but will also allow the aviation industry to advance our shared goal of reducing the dependency of our nation on foreign oil.

Filing an Article 84 action at ICAO has worked to address difficult environmental issues before and the United States should take the lead again. We believe the Administration has all the tools necessary to prevent the EU ETS from implementing its unilateral scheme, and thus should support the passage and approval of the bipartisan S. 1956, the “European Union Emissions Trading Scheme Prohibition Act”. As the aviation sector did during the hushkit dispute and in the ICAO work on the Chapter 4 noise standard and Balanced Approach policy, we are committed to working with the Administration to see the wrong measure overturned in favor of the right one.

Sincerely,

Aerospace Industries Association

Aircraft Owners and Pilots Association

Air Line Pilots Association

Airlines for America

Airports Council International - North America

American Society of Travel Agents

Cargo Airline Association

Consumer Travel Alliance

General Aviation Manufacturers Association

Global Business Travel Association

Independent Pilots Association

Interactive Travel Services Association

National Air Carrier Association

National Air Transportation Association

National Business Aviation Association

Professional Aviation Safety Specialists

Regional Airline Association

U.S. Chamber of Commerce

U.S. Travel Association

A4A supports a truly comprehensive, meaningfully balanced U.S. energy policy and is committed to protecting our planet.