Why the argument that flying does not add to carbon emissions – because it is all taken care of by the ETS – is wrong

An article appeared in the Telegraph on 30th January, by Louise Gray, reporting on a paper by an Economics lecturer at the University of East Anglia (UEA).  It was about consumer behaviour in relation to carbon emissions, and makes the case that cutting down on flying has no effect on total EU carbon emissions, as flying is taken into account in the Emissions Trading System (ETS). It also made out that other actions, like reducing use of electricity also have no effect, but cutting consumption of meat, reducing use of petrol or diesel, or using less gas for house heating would have an impact – as those sectors are outside the ETS.  Being told that flying has no impact on climate is an appealing message. However, many commentators have explained that this just is not correct. The ETS would only have this effect if the system was working optimally, which it is not.  It would only work if the caps on carbon were tight, and tightening (which they are not at present) and if the price of carbon was high (it is at an all time low at present, at around €2 – 3).  The non-CO2 emissions from flying are not taken account in the ETS.  Therefore the argument that not flying has no effect is not borne out.  It is just not correct.


The original article from the Telegraph is:

“Why flying could produce less carbon than taking the bus”

If you really want to stop climate change you would be better to give up red meat than stop taking flights, according to a new study. 

By , Environment Correspondent (Telegraph)    30 Jan 2013

The article contains statements such as:

“Dr Grischa Perino, an economist at UEA’s Centre for Behavioural and Experimental Social Science, said new EU rules means the decision not to fly does not cut overall carbon.

He explained that the carbon used by taking a flight are covered by the EU Emissions Trading Scheme.

This allows certain sectors to produce a limited amount of carbon over time. If less carbon is produced then the sector will sell their “permits” to another polluting industry in the scheme.

Therefore if you choose not to take a flight, all you do is “make it cheaper for someone else to pollute”, said Dr Perino.

“The net effect is zero,” he said. “If I do not fly someone else buys the permit I did not use and uses it to produce carbon.

“If you care about the change in total greenhouse gases, whether I fly or not is irrelevant because that is a fixed amount [set under the EU ETS].”

Taking a bus or a diesel train instead could even increase your carbon footprint.”



Prof Corinne Le Quéré, director of UEA’s Tyndall Centre for Climate Change Research, urged consumers to continue their efforts to reduce their carbon footprint.

“It is critical that we significantly reduce our carbon emissions to tackle climate change,” she said. “Reducing our individual energy use, particularly that of our travel, our houses, and our appliances, is the quickest and easiest way to reduce our own carbon emissions.”




In a nutshell, some of the key arguments against the Dr Perino idea are:

1. The ETS is not working well, and currently is hardly working at all.

2. The price of carbon needs to be a lot higher than its current all time low of €2 – 3 for the system to work.  Currently it is cheaper to emit carbon and pay for it, rather than to pay for measures to cut emissions.

3. The inclusion of aviation within the ETS is currently under attack, with countries such as the USA, China and India – with many others – attempting to prevent the EU ETS from charging their airlines for carbon allowances, for flights into and out of  Europe.

4. By the end of this year, the inclusion of aviation within the ETS is likely to be different, and the system is likely to be weakened – and less effective than planned.  It hardly even works now – so further weakened, it may be almost useless.

5. Airlines get 85% of their carbon allowances free, and only have to buy 15% of them.  Aviation has its own separate carbon allowances, called EUAAs (EU Aviation Allowances). These are in addition to the normal EUAs (EU Allowances). Airlines cannot sell EUAAs to any other sector; they are only for aviation. However, they can buy allowances from elsewhere.

6. The non-CO2 impacts of air travel are not taken into account by the ETS. These impacts (NOx and cirrus cloud mainly) approximately double the climate change impact of the CO2 alone.  A one for one purchase of carbon permits needs to take that problem into account, but it does not.

7. Aviation, as other sectors such as electricity generation, need additional policies and emissions targets.  Governments do not expect that the ETS caps themselves will be sufficient to bring down emissions.  For example, if carbon-trading can save the planet by itself, then why invest in renewables at all?

8. There are social implications of flying, or not flying. The choice of lifestyle/consumption habits shows elected governments that there is popular support for action.The current cap on aviation emissions (97% of the level in 2004 – 6) falling to 95% of it, is not enough to get real cuts in emissions. Unless citizens put pressure on EU politicians to lower the cap progressively, the cap will remain too high. It is up to ordinary voters to express their concerns about carbon emissions to their representatives, to get the system made better. Individuals choosing not to fly helps to demonstrate that ever increasing flying is not inevitable.

9. EU ETS is one “means to an end” of reducing aviation carbon emissions. Not the only one.  The way the system is meant to work ultimately, if the price of carbon rises to a high level, is to reduce demand for flying because improvements in aircraft fuel efficiency, improvements in air traffic control and the cul-de-sac of biofuels will not by themselves be enough to actually reduce the CO2 emissions if the industry grows substantially over the coming decades.

10. As aviation has its own set of EUAAs, if enough people did not fly,  all the affected airlines would have surplus permits, which could only be sold to other airlines. These spare permits could not be sold to other sectors, so they could not be used to allow higher emissions elsewhere.  These cuts in flying would be real cuts in overall CO2 emissions.

Photo from Turn Europe Green, on Facebook

and so it is with avoiding hypermobility – when thousands cut down on their flying, change can happen.


This issue is explored at length in an article by Leo Hickman, in the Guardian, on 31.1.2013

Should we stop worrying about the environmental impact of flying?

A University of East Anglia economist has provoked debate by arguing that flying within Europe has ‘no impact on total emissions’





The article is worth reading in full, but it is long, and comprehensive.  Below are a some extracts from it:

 Yes, within an enclosed system of tradable “permits to pollute”, it should not make a material difference where the source of the pollution comes from, as long as the overall total is strictly and verifiably capped.

But Perino appears to adopt a theoretical, idealised vision of the ETS, one that doesn’t account for the system’s very real flaws, not least its vulnerability to turbulence caused by vested interests and political pressure. And what account does it take of the current record-low price of carbon within the ETS? Or the fact that airlines actually made a huge windfall profit from the scheme last year? To say that the ETS is currently working in the way it should be is to side-step reality. (This week, UBS said that the EU ETS was “worthless” and “won’t work until 2045” without a change in the rules to tighten supply and curb a record glut of permits.) And why avoid discussing flights that travel in and out of the EU – a subject that forced the EU into making an embarrassing climbdown last November?


So what does Perino propose are, in fact, the green consumer’s best options?

With a cap-and-trade scheme in place, green consumers are left with three options to reduce total GHG emissions.

First, they can reduce emissions not captured by the EU ETS, e.g. by driving less or by eating less red meat.

Second, they can influence the political process via voting and lobbying to reduce the cap on regulated emissions.

Third, they can buy EU ETS allowances (or other types of offsets) and retire them and thereby have a direct impact on total GHG emissions.


Here are the thoughts of Bryony Worthington, the Labour peer who also enables people to “retire” ETS allowances through her organisation Sandbag.org. She seems to concur with Perino’s last two points:


Voluntary cancellation of allowances is an additional action individuals can take in and of itself. Government should do more to promote and encourage this including through introducing tax breaks. Sandbag’s carbon destruction service makes this possible and easy.
The ETS is currently under review if people are upset about how it impacts on their ability to make a difference. Now is a good time to lobby for these changes. Voluntary action can complement the upstream policy but it does not at the moment. It’s high time for a change.


I also asked Jeff Gazzard for his reaction. Gazzard, a board member of the Aviation Environment Federation (AEF), is a veteran anti-aviation campaigner who has long been closely following the formation and implementation of the EU ETS:

The UEA analysis is yet another well-meaning but essentially ivory tower piece of academic research that naively over-emphasises the potential that including aviation emissions in an ETS will bring.

In a UK context, the last government, having done all the negotiating to agree aviation’s inclusion in the EU ETS, rightly went on to ask the CCC [Committee on Climate Change] to assess how emissions from UK aviation could be brought back down to 2005 levels by 2050.

The CCC’s advice was to constrain demand growth.  The result of unconstrained CO2 emissions from both domestic and international aviation to and from the UK is proving hugely difficult to fit within our legally-binding economy-wide emissions reduction targets for 2050.

This analysis is simple, unassailable mathematics – the CCC’s aviation emissions report is world class and in fact should be extended to give us a global insight in respect of aviation emissions and the necessary control and reduction strategies through to 2050 to enable a fit within climate change strategies.

The CCC analysis forecast a 35% reduction in carbon intensity from technology, operational and ATM [air-traffic management] gains; those efficiency improvements would allow growth in flights of 55%; and a passenger demand increase of up to 60% from today’s levels would be achievable under a UK annual target for aviation emissions of 37.5 million tonnes of CO2.

Subsequent research by AEF suggests that the UK already has sufficient airport infrastructure to cater for 100% of the demand growth that CCC said was possible under the UK cap.

What’s the relevance of all this to EU ETS? In fact the UK-wide emissions target that was the basis for the CCC’s advice is very similar to the emissions cap imposed by the EU ETS, which limits aviation emissions to 95% of their average level between 2004 and 2006.

It’s true that the EU ETS cap allows airlines to buy permits from other sectors while the proposed UK cap did not, but the CCC’s forecast is that by 2050 we will all be living in such a carbon-constrained world that there will be very few permits around to sell.

EU ETS is “a means to an end” – as the carbon price rises (some hope!) for all sectors it will have a demand impact because we already know that aerospace technology, ATM improvements plus the cul-de-sac of biofuels will not by themselves be enough to actually reduce emissions as aviation CO2 rises.

ETS fills that gap a little; but the aim is not to allow unrestrained carbon growth from aviation – aviation caps will increase, the cost of carbon will rise, other sectors need ETS permits too, you get the picture.

At least that’s the “policy promise” – at 62 years old right now, I am unlikely to be around in 2050 to see if all this has worked!

Looking across to another vital and arguably even more important sector – given that we boil kettles slightly more often than we fly! – if carbon-trading can save the planet by itself, then why invest in renewables at all?

Why not just let the electricity generating-industry purchase permits and away we go, which seems to be the UEA argument.

Obviously, this isn’t what’s happening in power generation – you need to pull all the levers, carbon pricing, efficiency, renewable and so on and, yes, this includes onshore wind farms, Daily Mail readers please note. As with aviation, merely having the ETS is not enough – other policies and controls are required.

And don’t forget that most ETS and emissions reduction targets are set to try and avoid dangerous climate change and keep CO2 below 450 ppm by 2050, which in itself is a goal that needs urgent revision.

Finally, it must be remembered that the entire global aviation industry is busy trying to collapse the EU ETS as we speak.

In Montreal this week and next, the UN body charged with finding a solution to aviation emissions, ICAO, is “busy” wrestling with this issue. Except as probably the very best example of a producer-captured institution ever in geo-political history, it and its member states simply provide a talking shop for fig leaf “business as usual” rhetoric that would be embarrassing if those present could  be embarrassed, which simply isn’t possible, I’m afraid.

So what to do?

Some concrete examples: WWF UK’s “One-in-Five” campaign is a really good try at influencing real reductions in business travel and using video conferencing instead; please don’t fly around the UK or to our nearest European neighbours, take the train instead; and perhaps one year in three, why not take a holiday in the UK. A positive note to end on, I hope.


Here are the thoughts of Chris Goodall, author of a number of books examining green orthodoxies/unintended consequences, as well as the host of the Carbon Commentary blog:

In the nicest possible way, I’d want to say that this is a good and powerful argument, but it’s an economist’s argument. (“I can fly because the emissions caused by my flight mean that emissions elsewhere have to be reduced under the ETS scheme.”)

Actually, people don’t behave like economists expect them to do. Choosing an ethical lifestyle or a ‘green’ lifestyle has two effects simply not captured by economists.

First, it demonstrates a willingness to pay some price to achieve what one considers a social good. (Sorry, I’m talking like an economist here). If I say I won’t fly, it demonstrates to others that their might (just might) be an issue with flying. In other words, there may be (in fact, probably is) a demonstration effect. We are all strongly guided by the ethical actions of those around us.

Second, the choice of lifestyle/consumption habits shows elected governments that there is popular support for action. If, say, a substantial number of people said that they were reducing their flying for environmental reasons it allows governments to impose tighter caps on flying emissions, knowing that they have some popular support. (Frankly, I think this is the most important effect of ethical actions).

Whenever I give talks I’m afraid I always bang on about how ethical non-conformers have – throughout history – been the primary force for social improvement. Economists have had no similar impact. (Spoken as someone who briefly taught economics at university…)


Finally, here are the thoughts of Dr John Broderick, a “knowledge transfer fellow” at the Tyndall Centre for Climate Change Research where he specialises in carbon trading and emissions accounting:

I’m a little surprised to read [this discussion paper]. As I’m sure you’re aware, these “new EU rules” have been in force since 2005!  I’m not quite sure what the news is here. Three more engaged points:

i)  It says nothing about the actual state of the EU ETS which is currently so long/oversupplied in permits that it offers little constraint on emissions, if at all.

ii)  It ignores the dynamic effects on business models and infrastructure – in the short term, providing revenue to Ryanair (or conversely Eurostar or Hertz) to support particular routes and marketing campaigns. And, in the long term, in “predict and provide plans” for new “necessary” infrastructure and the normalisation of hypermobility.

iii)  EU ETS doesn’t account for other non-CO2 warming effects from aviation. The physics of the climate doesn’t warrant the use of a simple 2.7x “uplift factor or multiplier”, although that is a convenient representation, but aviation makes a greater contribution and this must be recognised.

My first point is the most important and the most intuitive. If the cap is so high that we won’t use up all the carbon permits then each additional flight is additional emissions…

Emissions trading sounds like a compelling idea in principle but the practicalities are much less attractive. Recently it’s been a godsend to aviation; despite the furore with Chinese and US airlines, it’s depoliticized over-consumption (i.e. we are told it no longer matters who causes what harms, provided we all pay the right amount) and in the UK obviated the need for government to face up to a problematic sector.

These may look like “mere” ethical issues at the moment, but as this story highlights, emissions trading carries a series of practical problems. A weak cap means increased emissions but a tight cap, based on a effective climatic targets would likely lead to regressive social consequences, for instance, privileging a Londoners’ stag party over a Polish OAPs’ warmth.


Personally, I feel Perino’s discussion paper serves to remind us, as “green consumers”, that we must constantly re-assess our assumptions, habits and decision-making. We are having that “discussion” now, so, on one level, his paper has performed its function. But, like the other commentators here, I believe his argument ignores the reality of how the EU ETS is performing.

Yes, as WWF coincidentally concludes in a report published today on “Market Based Mechanisms to Curb Greenhouse Gas Emissions from International Aviation” (pdf), a global cap-and-trade system is probably the best way to meet aviation emission reduction targets over the coming decades.

But we are still a very long way indeed from seeing such a mechanism implemented in full. Therefore, it is still far too premature – and risks complacency – to start abdicating our responsibility when it comes to attempting to reduce the emissions caused by our lifestyle choices.





The  press release 30.1.2013  from UEA about the paper by Dr Perino is at
His paper is Private provision of public goods in a second-best world: cap and trade schemes limit green consumerism, by Dr Grischa Perino
The paper’s Abstract states:

Private provision of public goods can only supplement government
provision if individual actions affect the level of the public good. Capand-
trade schemes reduce the overuse of common resources such
as a stable climate or fish stocks by imposing a binding cap on total
use by regulated agents. Any private contributions provided by
means of e.g. green consumerism or life-style choices within such a
scheme only impacts on who uses the resource but leaves total use
unaffected. Perfect offsetting of marginal contributions is a key
design element of cap-and-trade schemes. As real world cap-andtrade
policies like the EU Emission Trading System have incomplete
coverage, understanding what they cover is crucial for individuals
aiming to contribute. Otherwise contribution efforts backfire.




Why the emissions from flying are NOT entirely taken account of by the ETS

Why part of Dr Perino’s thesis is wrong.

The “flying is carbon neutral” concept rests upon the ETS compensating it out   i.e. it does not matter how much carbon you cause to be produced in any carbon traded sector, as someone else will pay to reduce that carbon somewhere else.

This might be fine if carbon trading worked – it does not currently because the price of carbon allowances is too low to pay for reduction measures, there are a lot of “hot air” credits in the system that don’t actually reduce anything, and there are dubious imports into the system from places that are not actually making a reduction.

So – on that basis any activity that increases your carbon output, traded or not, is a bad thing.  ie in reality, extra real physical carbon is not being compensated for by theoretical carbon reduction.

This also ignores that the trading only covers EXTRA flights above the baseline – if everyone flew less then this would reduce total emissions, which would fall below the baseline so carbon trading would not apply.

The electricity sector does not only operate through ETS – as a traded sector it also has a target to reduce emissions itself as well as to reduce the overall total through trading (but the Government has ducked setting an absolute decarbonisation target for now). This sector reduction does depend upon actions by citizens such as changing light-bulbs, insulation etc. The same principle applies for air travel.
The author, Dr Perino, is an economist, and is looking at the issue from a purely theoretical, economic perspective.  He suggests that instead of buying low energy bulbs or flying less we should write to our politicians asking them to tighten up the EU ETS caps. Which makes sense, but it avoiding the issue.
The argument  about flying, or light  bulbs, would be true if the EU ETS worked properly and had caps that were determined by the latest science rather than by politics and what markets will bear.
If everyone cut their electricity use and cut down flights THEN the politicians might consider tightening up EU ETS caps as it would send the message that voters could cope with these changes.
If people did not fly, and also “retired” some carbon permits – buying them to remove them from the system – that would indeed help to limit the supply.