Here is the cover letter for my public comment on the International Civil Aviation Organization (ICAO) offsetting scheme, called CORSIA. The UN agency has received 14 proposals for offsetting programs, and seeks public comment on whether they satisfy evaluation criteria. Perhaps the most difficult criterion, which the proposals I read do not meet, is the additionality criterion. I first heard about the open comment period yesterday.

Dear ICAO:

Here attached are my public comments on the first 5 of the 14 offset proposals (ordered alphabetically). Insufficient time was provided in the public comment period for me to read the remaining proposals.

The due date for comments is Sep. 5, and the first notice I can find announcing the open comment period, anywhere on the internet, is Sep 3. Because the ICAO website does not give an opening date for the comment period, and the ICAO Twitter feed does not contain any announcement of the comment period, I can find no evidence that this comment period was longer than 2 days. Clearly, this is not proper procedure.

Overall, the approach to additionality is not credible. Every sector of society is rapidly paying more attention to the climate crisis. Across the board, the baselines used in these proposals take insufficient account of future actions by external actors (outside of the offset scheme) that will simultaneously be seeking to affect emissions.

To give just one example, suppose an offset program funds fuel-efficient wood stoves to replace open cooking fires in a low-income country. The proposed “additionality” certification states that, in the absence of the offset program, households would continue to cook on open fires. The full emissions reduction from the change to new stoves is credited to the offset program as “additional.” But this is not plausible. In a time of climate crisis, countries around the world are rapidly expanding electrification, and the electric grid in turn is relying more on renewables. Rural people in low-income countries are moving by the millions to cities, where they are more likely to have electricity. To assume the households would all continue using cooking fires is not plausible. So the offset scheme gets credit for far more emissions reduction than was in fact achieved.

This problem is pervasive in the proposals I read today.

Here are my comments in the format of your official rubric, on just 5 proposals, but but my public comment greatly understates the deep emptiness of this offsets approach.

What really is needed from ICAO and CORSIA is actual emissions reductions within the aviation sector. It is a travesty that ICAO only provides overall goals for emissions “net” of offsets, and will not state goals for actual emissions reduction in the aviation sector.

Sincerely,

Parke Wilde

Among the 14 proposals, the Clean Development Mechanism (CDM) sent what appears to be a cover letter. I could not find any proposal in the required format. The cover letter did not mention the additionality criterion, as far as I could tell. The CDM’s ability to deliver additionality has been criticized in the past: How Additional is the Clean Development Mechanism?

In the New York Review of Books yesterday, Rebecca Tuhus-Dubrow puts her finger on what is so distinctive about aviation in a time of climate change:

Aviation has long enjoyed a kind of exceptionalism. Many people who take pride in their green lifestyles—perhaps they bike to work and always carry a travel mug—also happen to be frequent flyers. This incongruity grows in part out of cultural factors. A certain type (and I count myself in this category) aspires to be both worldly and socially conscious. We would never think of driving an SUV, say, but we’ve been known to drop the names of far-flung capitals we’ve visited. To be sure, our portable bamboo utensil sets and canvas grocery bags accord with our principles, but they also accord with our self-image, our aesthetics, our personal brands.

The article covers our university-centered petition, which now has 670 academic supporters. See also Twitter handle @flyingless and FAQ.

Parke Wilde, a food economist at Tufts University, and Joseph Nevins, a geographer at Vassar, established a petition, asking universities to take measures to reduce flying by faculty, staff, and students “commensurate with the cuts suggested by climate science.” …

To some environmentalists, particularly in the UK, there was a simpler, albeit not especially appealing, answer: If you want to prevent the damage caused by flying, you shouldn’t fly. Beyond Flying, an anthology that appeared in 2014, included essays mainly from British writers and activists, all of whom had changed their flying behavior as a result of climate concerns.

That book was pivotal for Parke Wilde, the Tufts food economist. Starting about a dozen years ago, he had begun to consciously reduce the number of flights he took. Then, inspired by the anthology and a couple of other non-flying academics—Kevin Anderson, a climate scientist in the UK, and Nevins, the Vassar geographer—he decided in 2014 to stop flying altogether. Wilde and Nevins run a blog titled Flying Less.

Non-flying academics can’t help but notice a conspicuous tension between, on the one hand, the espoused values of universities and professors, and, on the other, the flying behavior that is condoned, incentivized, and relished at their institutions. Professors are not especially highly paid, considering their educational credentials, and getting flown out to give talks and hobnob at conferences in destinations such as Berlin, Bangkok, or Johannesburg is a major perk of the job. At the same time, even if they would prefer to stay put, junior faculty members feel pressure to travel, in order to schmooze with colleagues and promote their work.

With their petition, which currently has signatures from more than 600 academics, Wilde and Nevins ask both universities and professional associations to take steps to modify this system. One idea they propose is the “regional hub” conference model, in which academics would congregate in their respective regions for personal connections and use video-conferencing to interact with other hubs. A few of these associations have begun to consider experiments with the conference model, which, after all, has remained static for decades—why shouldn’t it change in the face of both new technological options and new environmental imperatives?