Weighing costs of regulatory regimes when molehill CO2 emissions are falsely paraded monstrous threats
 One bureaucratic craze we all are encouraged to adopt is the drive towards zero carbon dioxide emissions. The aviation sector has been singled out to shoulder a biggest share of the burden because it produces disproportionately more aerosolized CO2 worldwide than other sectors.
Like it or not, there are legal and regulatory mandates, as well resulting market incentives for cutting back on carbon. The UN's International Civil Aviation Organisation (ICAO) wants aviation's net CO2 emissions to reduce 50 per cent of 2005 levels by 2050. To this end, it launched CORSIA (Carbon Offsetting and Reduction Scheme for International Aviation) requiring operators to buy carbon credits.
While admiting the costs will be considerable, the bureaucrats say compensation lies in new fuels and aviation technologies that will come later, though hopeful specifics in this area will also come later.
But before getting into that, one asks what is so frightening about unrestrained CO2 emissions, anyway? Why the fuss? Why must we do something now? From where does the imperative spring?
Turning to Google for an answer that question, we learn of CO2's impact on the environment. "CO2 has proven to be a significant contributor to air pollution, taking a substantial role in the greenhouse effect. That's because carbon dioxide traps radiation at the ground level, resulting in ground-level ozone. That prevents the earth from cooling during the night and warms ocean waters."
If that is an existential threat, as it is so often claimed, that is, a threat to "people’s existence or survival" then it must be an very distant one because sunny days have produced cooler nights from Montreal to Melbourne since the dawn of time and show very sign of doing so for centuries to come.
And as to the impact of CO2 on the individual, to quote Google again: "Exposure to CO2 may include headaches, dizziness, restlessness, a tingling or pins or needles feeling, difficulty breathing, sweating, tiredness, increased heart rate, elevated blood pressure, coma, asphyxia, and convulsions." The last three are admitedly scarifying, but massively mitigated by the verb "may".
Like the dawning of the Age of Acquarious, all will be put right, bureaucrats say, with advent of Sustainable Aviation Fuel (SAF). This is a blend of Jet A1 fuel with up to 50 per cent renewable hydrocarbons, from plant or animal material, used cooking oil, municipal waste and agricultural residues. Once expensively blended, SAF can be cheaply "dropped in" to existing aircraft tanks, ideal for use in new and older aircraft well suited for the air cargo fleets.
While there is reason to hope for relief as 50 per cent renewable hydrocarbon deadline does not kick in till 2050, as intervening elections may produce different policy outcomes to unsettle bureaucrats. At the same time, there is still the ICAO to crack the whip to ensure incremental progress by operators.
But the cost of SAF is twice as high as that of conventional jet fuel and higher than that of sustainable alternative fuels used in other transport modes. There are also scalability problems of SAF production.
To put this in perspective, London's Flight Global reported that, “more than one airline chief executive has pointed out in recent months that even if they each took all of the world’s available SAF this year, it would only power their fleet for a few days.”
London-based HFW law firm, formerly Holman Fenwick Willan, lawyers Zohar Zik and Matthew Gore, writing in Lexology.com, about CO2 emissions affecting air cargo, said freight sector "faces unique challenges on the path to net zero".
Outlining the challenges, the two lawyers said: "Methods of carrying air freight have changed in the post-pandemic world. Before 2020, 50 per cent of cargo was belly freight (on board passenger aircraft). However, by mid-2020, with passenger numbers through the floor and a boom in global e-commerce, this had dropped to around 20 per cent, with the extra capacity provided by dedicated cargo aircraft. This trend is expected to continue," they said in their Lexology article.
"With air freight remaining a cost-sensitive, low-margin industry, this dichotomy lies at its heart," they said.
Aviation consultancy IBA, they said, reported that the active freighter fleet grew in 2020, with observed growth in 2021 and the market is on a trajectory of continued growth and increasing numbers of freighter flights.
"To meet the demand for capacity, freight operators are acquiring additional aircraft. These aircraft are unlikely to be new – most operators prefer to use ageing passenger planes and convert them into freighters, thereby securing a lower capital cost, which in turn enables them to remain competitive. This however comes with a disadvantage that such aircraft are by and large less environmentally friendly, in terms of both fuel consumption and noise.
"On an industry level, the “BlueSky programme” has been launched as a response for the call to create a dedicated tool to measure the progress towards the sustainability goals. This was designed by The International Air Cargo Association (TIACA) and is being promoted as the air cargo industry’s sustainability assessment, validation, and verification programme.
CORSIA is part of a four-pillar supranational strategy which also includes improvements in technology, operations and infrastructure. In all global markets, government support will be key with investment at the necessary levels into research and development.
"Although a great deal of work is needed to ensure a sustainable future for the air freight industry," the HFW lawyers said, "there is already a big push from air freight carriers, airports, and supply chains, both voluntary as a result of an increasing awareness of corporate responsibility, and in response to tighter regulation."
"Momentum is gathering in relation to the production and trading of SAF and associated regulatory obligations and incentives. SAF, while not a complete answer yet, is the shorter-term focus while the development of new airframe technology remains a more distant solution. The air freight industry cannot evolve in a vacuum. Close co-operation and co-ordination with supply chains, as well as strong focus on the connection with road and rail will be necessary to achieve a truly sustainable air freight industry," they said in conclusion.
What they did not say, and what is seldom said, is that larger operators welcome these new rules. While they may go some way in "saving the planet", they also serve to heighten regulatory compliance costs to levels smaller rival operators can no longer afford, thus deliverying greater market share to bigger players when smaller fry go out of business.
While it is only sensible to be cognizant of the HFW lawyers' advice, given the immediate bureaucratic danger, it may also be time to question the supposed wisdom underpinning this extreme regulatory environment and ask "cuo bono" - who benefits? |
