For generations, flying has contributed to a better quality of life in America. Commercial aviation has been essential to the growth of our economy, yielded breakthrough technologies, brought people together and transported critical cargo – all while achieving an exceptional environmental track record. No industry is better positioned to stimulate the nation’s economy while constantly enhancing its environmental performance.
U.S. Airlines: Green and Getting Greener, Catalyst for Economic Growth
Today’s airplanes are not just smarter – they are quieter, cleaner and use less fuel than ever – but we also fly them smarter. That’s why our industry represents just 2 percent of all GHG emissions in the United States while driving three times more economic activity – nearly 6 percent of the nation’s GDP. But we are not stopping there. The initiatives that we are undertaking to further address GHG emissions are designed to responsibly and effectively limit our fuel consumption, GHG contribution and potential climate change impacts while allowing commercial aviation to continue to serve as a key contributor to the U.S. economy.
For the past several decades, commercial airlines have dramatically improved fuel and GHG efficiency by investing billions in fuel-saving aircraft and engines, innovative technologies like winglets and cutting-edge route-optimization software. For example, between 1978 and 2007, the U.S. airline industry improved its fuel efficiency by 110 percent,[1] resulting in 2.5 billion metric tons of GHG savings – roughly equivalent to taking more than 18.7 million cars off the road in each of those years. Further, data from the Bureau of Transportation Statistics confirms that U.S. airlines burned almost 3 percent less fuel in 2007 than they did in 2000, resulting in absolute reductions in GHG emissions, even though they carried 20 percent more passengers and cargo on a revenue-ton-mile basis.
At the same time, commercial aviation is critically important to local, national and global economies, enabling a large percentage of U.S. economic output. A July 2007 study by the Federal Aviation Administration (FAA) found that the national economy is highly dependent on commercial aviation, which is directly or indirectly responsible for $1.1 trillion in U.S. economic activity (gross output), an estimated 9.5 million jobs, and $322 billion in earnings.[2]
Placing our economic output side by side with our GHG output, it is clear that commercial aviation is an extremely GHG-efficient economic engine, bringing good “bang” for our GHG “buck.” And we are committed to continuing that performance. As a cornerstone of our energy and environmental initiatives, the ATA airlines are committed to achieving, at a minimum, a 30 percent improvement in fuel efficiency from 2005 levels by 2025.
Airlines have an inherent economic incentive to reduce fuel consumption and the resulting GHG emissions because fuel accounts for a significant and volatile part of an airline’s operating budget. With a nearly $60 billion fuel bill in 2008, airlines pursue every opportunity to conserve fuel, thereby reducing emissions. Along with environmental gains, stable energy prices are critical for a stable and viable airline industry, which begs for a committed energy policy of independence and alternative fuels. However, enormous amounts of capital and committed research and development are required to advance science and technology, all of which are essential to new sources of energy, further fuel efficiency gains and
GHG reductions.
Congress Can Ensure Aviation Has the Tools to Continue Improving Efficiency
Rather than impose a punitive tax on the fuel necessary to operate our air transportation system, Congress should pursue initiatives that will enable airlines to continue to significantly reduce fuel consumption and GHG emissions. Without question a healthy airline industry is better positioned to make the necessary investments in cleaner aircraft and new technologies. Real environmental gains can only be accomplished through the collaborative efforts of the government, aviation manufacturers, energy companies, airlines and other stakeholders working together.
- First, it is critical to accelerate the implementation of a Next Generation Air Traffic Control System (“NextGen” ATC will become “NowGen” ATC).
- Second, it is vital that an energy policy is adopted by government that provides for stable supplies, stable prices, independence from foreign oil, and is more climate-friendly. In particular, alternatives to crude-oil-based jet fuels are imperative.
- Third, it is critical that new airframe and engine technologies be researched, developed and delivered.
With the enactment of these three initiatives, air transportation will be more fuel efficient, more affordable and more able to contribute to domestic economic and job growth.
NextGen: A Satellite-Based Air Traffic Control System Will Reduce Emissions Up To 15 Percent
“NextGen” includes a wide range of technologies and procedures to transform today’s antiquated ground-based air traffic navigation and surveillance system to a state-of-the-art satellite-based system. The cornerstone of NextGen is ADS-B, or Automatic Dependent Surveillance-Broadcast, that uses satellite technology to allow aircraft to constantly broadcast its position to other aircraft and air traffic controllers. When coupled with RNAV and RNP navigation aids/procedures and other technologies, aircraft will fly more efficiently and the system will see tremendous environmental, safety and capacity improvements.
Today’s antiquated ground-based systems add flight time because they do not route aircraft in a direct, linear fashion. Further, because today’s technology does not precisely pinpoint an aircraft’s position in space, a greater amount of time and separation must be factored in spacing flights apart. Utilizing satellite-based systems, the FAA and airlines will be able to route flights more efficiently, precisely and directly. This reduces flight miles, flight times, congestion and delays. Less aircraft time in the air and on the ground means significantly lower fuel consumption and GHG emissions.
The time to act is now – accelerated ATC modernization is a doable, pragmatic way to address aviation emissions. Congressional and FAA leadership, sufficient government investment in incentives and proven technologies can transform the system in a matter of years, not decades. Projections of fuel consumption and GHG emissions reductions from full NextGen implementation are significant and range as high as 15 percent. ATC modernization should be a top priority, yielding measurable benefits for the environment, air travelers and shippers, and the nation’s economy.
Alternative Energy – A Potential Game-Changer
Today, the aviation industry is dependent on crude oil as its source of jet fuel. Unlike other sectors of the economy, airlines currently have no alternative but to consume jet fuel. To address this reality, ATA supports a balanced and comprehensive national energy policy that increases U.S. energy independence and results in more predictable and stable energy supply and costs.
ATA and other aviation stakeholders have taken the initiative to develop and deploy commercially viable, environmentally friendly alternative jet fuels through the Commercial Aviation Alternative Fuels Initiative (CAAFI). The federal government can assist the airline industry through the following actions:
- Certification assistance – A key step in alternative aviation fuel development is certification. Before the fuel can be approved for commercial use, it must meet rigorous safety and performance standards – much higher standards than fuel for ground-based transportation. Federal support is needed to accelerate the approval and deployment of several alternative aviation fuels that have already been developed and tested. Increased funding is also needed for ongoing U.S. military efforts to develop alternative fuels and biofuels for military jet fleets that will transition to commercial fleets.
- Infrastructure investment – Considerable ground and flight testing has demonstrated that commercial aviation is coming closer to the widespread use of alternative aviation fuels. However, the economic slowdown has dried up investment dollars for already conceived pilot plants and full-scale production plants. Direct federal support for such infrastructure investments and greater support in the area of research and development, including the feasibility of pipeline use for biofuel transport, will allow the development plans to proceed.
- Environmental assurances – Alternative aviation fuels will only succeed if they are found to be economically viable and more climate-friendly than today's aviation fuels. Direct federal investment is needed to develop criteria in test programs and models that will accelerate the deployment of alternative aviation fuels.
Aircraft and Airframe Technology
As ATA and its members are pushing the envelope with existing technology, we continue to contribute to work that will advance new technology. For example, ATA participates in key, joint government/ stakeholder initiatives, including the Steering Committee of the Partnership for Air Transportation Noise & Emissions Reduction (PARTNER) and the Environment and Energy Subcommittee of the FAA Research Engineering and Development Advisory Committee. While additional evolutionary environmental improvements are in the pipeline as a result of such initiatives, revolutionary environmental breakthroughs can only come about through the reinstatement of significant federal investments in basic aeronautics research and development programs at NASA and FAA. Indeed, Pratt & Whitney’s new geared turbofan engine, which offers both noise and emissions benefits, as well as many features of Boeing’s more environmentally efficient 787 were spawned through such programs. As we have noted in other contexts, however, congressional funding to NASA and FAA for aeronautics research and development – specifically including for environmental projects – has been cut significantly (by about 50 percent) in the past 8-10 years, compromising the public-private partnership for exploring and bringing to market products with significantly improved environmental performance.[3] Thus, we continue to urge Congress to provide this needed funding, which also is critical to preserving America’s competitiveness in aeronautics.
One-Size-Fits-All Cap-and-Trade Systems do not Fit Aviation
Cap-and-trade is often discussed as the solution to climate change. Under the major cap-and-trade proposals, which regulate transportation fuels “upstream” (i.e., at the fuel producer level), the airlines – and the transportation sector, in general – would be saddled with significant cost burdens through higher fuel prices. For an airline, higher fuel prices would negatively impact ticket prices, reduce service to both small and large communities, and the economic development associated with commercial aviation
(i.e., travel and leisure businesses, aircraft manufacturing, airport-related jobs, etc.), as well as the airlines’ ability to fund the purchase of new fuel-efficient equipment and technologies.
ATA is concerned that the draft legislation that the committee is considering could be counterproductive to the U.S. air carriers’ ongoing efforts to reduce their carbon output. However, there are several changes to the legislation that the committee should consider to lessen the detrimental impact the legislation would have on our industry.
International Civil Aviation Organization (ICAO): Key to the Global Sectoral Solution
The International Civil Aviation Organization (ICAO), an agency of the United Nations, by treaty is charged with establishing standards and recommended practices for international aviation and fosters the planning and development of international air transport to ensure safe and orderly growth.
Because of the inherently international nature of commercial aviation, the Kyoto Protocol expressly recognized that emissions from international aviation should not be included in national targets but should be addressed by ICAO. This is a clear acknowledgement that policies that work for other sectors do not always work for aviation, and that is particularly true for a challenge like climate change.
ICAO has formed the Group on International Aviation and Climate Change (GIACC), a 15-government (government-only) group charged with identifying additional measures for limiting GHGs from international aviation. The outcome of the GIACC work will be fed into the larger negotiations to replace the Kyoto Protocol. Accordingly, the GIACC is scheduled to have its fourth and final meeting on May 25-27, 2009, where it is expected to formulate recommendations for ICAO to adopt. The ICAO Council (ICAO’s governing body), is expected to consider these recommendations in the summer of 2009, with ICAO expected to finalize a policy position at a special meeting scheduled for October 7-9, 2009. Further, ICAO can also use its Assembly meeting in September 2010 to further flesh out the approach to international aviation and climate change if needed. To ensure that that aviation is not subject to conflicting and overlapping international and domestic requirements, Congress should refrain from imposing a domestic-only cap-and-trade system on aviation while it allows ICAO work to continue.
Money Should Be Reinvested in Carbon-Reducing Aviation Initiatives
While the full costs to U.S. commercial aviation of the of the ACES Act cannot yet be calculated, due largely to the fact that the draft legislation does not address how GHG emission allowances will be distributed, ATA estimated that the Lieberman-Warner legislation considered by the Senate in the last Congress (S. 2191) would have cost U.S. airlines $5 billion in 2012 and increased from there. As indicated above, the competitive nature of the U.S. airline industry – and the significance of fuel in the operation of airlines – provide a strong and inherent incentive for airlines to increase efficiency, burn less fuel and emit less carbon. The industry has a proven track record of efficiency improvements over the past 30 years and removing financial resources from the industry will only serve to make it more difficult for airlines to get cleaner.
For this reason, it is imperative that any funds that a cap-and-trade regime siphons away from the airline industry in the form of higher fuel prices be returned to that industry in ways that will assist it in reducing emissions. This certainly includes assistance in:
- Retiring old, less-efficient aircraft with newer and cleaner models;
- Assisting airlines in retrofitting existing planes with new avionics, airframe components and engines;
- Greatly accelerating the development, certification and commercialization of a low-carbon alternative aviation fuel that will work with existing engines and infrastructure; and
- Fast-tracking the implementation of a satellite-based, 21st century air traffic control system that greatly improves the efficiency of all aviation in this country. Projections of fuel consumption and GHG emissions reductions from full NextGen implementation are as high as 15 percent.
Safety Valve
Section 726 of the draft ACES legislation directs the EPA to create a “strategic reserve” of 2.5 billion metric tons of emission allowances by setting aside a small number of allowances from each year’s tonnage limit. It also establishes rules for releasing allowances from the reserve and for refilling the reserve if allowances from the reserve are sold. Clearly, this strategic reserve is intended to dampen the price volatility that will almost certainly occur within the carbon allowance/offset market. While ATA commends the committee for its acknowledgement that this is a significant issue, the mechanism that the bill seeks to implement is inadequate.
ATA supports a mechanism that would allow for the free issuance of allowances, for the transportation fuel market only, if the aggregate price of liquid fuel plus allowances, in any combination, exceeds a certain threshold. The theory behind a cap-and-trade system to reduce GHG emissions is that increased energy costs will incentivize decreased consumption and thereby reduce emissions. As we saw last summer, crude oil prices rose to greater than $147 per barrel and no further incentive was needed; energy consumption and emissions dropped significantly and industries like aviation were whipsawed and battered. All goals of the program will continue to be met if such a safety valve is included in the legislation, and vital industries like U.S. commercial aviation will be spared unnecessary harm.
Federal Preemption
Currently, states and localities are largely preempted from regulating most aspects of U.S. commercial aviation. They are clearly prohibited from establishing their own aircraft emissions standards and this preemption should continue and be expressly stated in any future climate change legislation. That said, ATA also supports full preemption of all state authority to impose regulations on the emission of GHGs. Climate change is not a localized problem but a global one. GHG emissions in a certain city or state do not cause unique environmental challenges for that locality because of where the emissions occurred. A ton-equivalent of CO2 has the same impact on the planet whether it is emitted in the U.S. or on the other side of the globe. There is no scientific rationale for allowing local standards.
Conclusion
I close by asking you to note the achievements that commercial airlines have made in reducing fuel burn and GHGs, particularly when compared to other industries, and the actions that we are taking to continue our progress in this regard. While ATA members are fully committed to working with Congress and are asking for congressional leadership and support in each of the areas I have described, we are asking you to work with us in addressing these environmental, energy and transportation concerns. This includes ATC modernization, which is a critical path to environmental improvements for aviation. We also are urging you to refrain from adopting policies that would work against our efforts. With your leadership, we can realize the resulting emissions savings sooner rather than later.
A vibrant, competitive and efficient aviation sector is a key part of the solution. It is not an impediment to creating a strong economy, freeing ourselves from foreign oil, and creating a cleaner, greener, healthier planet.
[1] In 1978, commercial airlines carried 2.92 revenue ton miles per gallon of fuel used. In 2007, commercial airlines carried up to 6.11 revenue ton miles per gallon of fuel used, an improvement of 109.6 percent.
[2] See FAA, The Economic Impact of Civil Aviation on the U.S. Economy (July 2007).
[3] While later funding cuts were even more drastic, a 2002 study by the National Academy of Sciences observed:
In constant year dollars, NASA funding for aeronautics research was cut by about one-third between 1998 and 2000, reducing the breadth of ongoing research and prompting NASA to establish research programs with reduced goals, particularly with regard to TRL (technology readiness level). This significantly reduces the likelihood that the results of NASA research will find their way into the marketplace in a timely manner, if at all. The ultimate consequence is that the federal expenditures are inconsistent with the long-term goal of support for an aviation enterprise compatible with national goals for environmental stewardship.
See National Academy of Sciences, Committee on Aeronautics Research and Technology for Environmental Compatibility, For Greener Skies: Reducing Environmental Impacts of Aviation at 44 (2002).
Click here for PDF (371 kb)