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The New York City Council today held a hearing on a suite of bills to limit noise from helicopter flights over New York City. The bill most pertinent to carbon taxing is a resolution supporting a proposed NY State $400 “noise tax” on flights taking off or landing at the city’s heliports.

My testimony, presented below, situates the proposed noise tax in the context of social damage costing, also known as externality pricing. Previous CTC posts in this vein have covered NYC’s forthcoming congestion pricing plan, a California growers’ program that taxes excess withdrawals of groundwater for farming, and Berkeley, CA’s soda tax.

Educator from the NYC harbor ecology group Billion Oyster Project, at the April 16 City Hall Park rally organized by Stop The Chop NY/NJ. To speaker’s left are Councilmembers Lincoln Restler and Amanda Farias, lead sponsors of Intro 70 and 26.

As can be seen from photographs of the rally prior to the council hearing, the anti-heli-noise outfit Stop The Chop NY/NJ takes a reformist position on helicopter flights. I’m more militant in both deed, having helped organize a human blockade of the West 30th Street (Hudson River) heliport last September; and in language, preferring the term “luxury fights” to Stop The Chop’s “nonessential flights.” 

That said, I tip my hat to Stop The Chop for their scrappy advocacy raising the profile of helicopters’ aural and other assaults on New Yorkers’ quality of life. The bills in question would almost certainly not have been written without their years of organizing.

Testimony of Charles Komanoff[1] supporting Council Bills banning nonessential helicopter flights using municipal properties, and Council Resolution 0085-2024 endorsing state legislation imposing a noise-annoyance surcharge on nonessential helicopter flights in New York City[2]. Submitted on April 16, 2024. (My statement has been lightly edited for clarity. Bracketed numbers denote endnotes.)

I emphatically support Council bills Intro 26 and Intro 70 banning nonessential helicopter flights from the two City-run heliports. In addition, as an economist specializing in environmental costing,[3] I’d like to single out for praise Council Resolution 0085-2024 endorsing state legislators Kirsten Gonzalez’s and Bobby Carroll’s bills S7216B and A7638B imposing a noise fee on nonessential helicopter flights.[4]

The Gonzalez-Carroll noise fee is $100 per occupied seat or $400 per flight, whichever amount is larger. Although these levies appear to fall short of the average helicopter flight’s full societal cost, they are a commendable starting point. The levies can be raised later on, as methodologies for quantifying helicopter noise costs mature — a process that will be aided by passing a related bill, Intro 27. The fees can also be lowered if quieter helicopters emerge — which the Gonzalez-Carroll bills will incentivize.

“Cost internalization,” as this kind of social-damage pricing is termed, is long overdue for helicopter noise. “Luxury” helicopter flights — a more apt term, perhaps, than “nonessential” — impose other costs like carbon pollution and particulate-exhaust pollution. Moreover, these flights are purely discretionary. Anyone taking a luxury helicopter flight — whether to the Hamptons or JFK or for sightseeing — has money to spare, as revealed by their pricey transportation choice. Taxing helicopter noise is entirely consistent with economic justice.

Consider Blade’s JFK helicopter service from its Manhattan West 30th Street heliport — a flight covering about 15 miles. I’ve made a preliminary but serviceable calculation suggesting that one such flight steals around $2,500 worth of peace and quiet from city residents.[5]

A more militant protest: Extinction Rebellion’s Sept 2023 human heliport blockade. See our post from that month, “Grounding Helicopter Luxury.” Photo: Christopher Ketcham.

The Gonzalez-Carroll noise fee offsets only a fraction of that damage. But it amounts to a roughly 40 percent surcharge to Blade’s $250 standard ticket price to JFK, making it a worthy start. Assemblymember Carroll has been a legislative leader on externalities taxing, and it’s great to see Sen. Gonzalez also taking up the cause.

A noise fee raising the price of a commuter helicopter trip by 40 percent will cut usage, hence, the number of flights, by 30 to 50 perceny,[6] as some would-be passengers opt out. (Yes, just like congestion pricing, except more draconian, and deservedly so). That will not only bring peace and quiet, it will generate $10 to $15 million per year[7] — revenue that New York City can use to expand and enforce noise-abatement rules citywide.

Noise isn’t the sole harm that commuter and tourist helicopters inflict on the millions of residents below. But it is the most egregious and insulting. Every member should vote Yes on the bills to ban nonessential helicopter flights from the two City-owned heliports. And please also vote for Council Resolution 0085-2024 to make clear to your Albany counterparts that New York City’s local elected officials support the Gonzalez-Carroll helicopter noise fee.

Endnotes.[8]

[1] Policy analyst and consulting economist at KEA, 11 Hanover Square, 21st floor, New York, NY 10005. Website www.komanoff.net.

[2] This document is available on line as https://www.komanoff.net/jet_skis/Komanoff_Testimony_City_Council_Helicopter_Noise_Costs.pdf.

[3] My work quantifying and supporting NYC congestion pricing is widely known; much of it is collected here. My body of research also includes Drowning in Noise: Noise Costs of Jet Skis in the United States, a monograph co-authored with Dr. Howard Shaw and published in 2000 by the Noise Pollution Clearinghouse.

[4] Assemblymember Bobby Carroll represents part of Brooklyn. State Senator Kristen Gonzalez represents parts of Brooklyn, Queens and Manhattan.

[5] Key assumptions in my calculation of a $2,500 collective noise cost per flight from W 30 St to JFK Blade include: 625,000 households in Manhattan, Brooklyn and Queens households lie within the helicopter noise field; excess noise of 20 dBA during the average 44 seconds of noise exposure for each flight; a “Noise Depreciation Index” — reduced property value per additional decibel during exposure — of 1%. Some parameters in the calculation are placeholder values, making the resulting $2,500 estimated per-flight collective noise cost preliminary and subject to change. See Excel spreadsheet referenced in final endnote.

[6] The 30 percent reduction is associated with a price-elasticity of helicopter flights of negative 1, while the 50 percent reduction comes from a price-elasticity of negative 2. The respective calculations are: 1.4^(-1) ~ 0.7, and 1.4^(-2) ~ 0.5. (My high price-elasticity figures reflect the discretionary and luxury nature of helicopter travel.) See Excel spreadsheet referenced in final endnote.

[7] The number of helicopter flights per year that would be subject to the Gonzalez-Carroll noise tax appears to be between 50,000 and 60,000 per year. I have used the lower figure (50,000) in my calculations. Taking into account that the incorporation of the proposed tax into the price of helicopter flights would be expected to reduce the number of flights by 30 to 50 percent, and applying a per-flight noise fee of $400, the annual tax revenues, rounded, calculate to between $10 and $15 million per year (50k x $400 x 50% or 70%).

[8] An Excel spreadsheet (NYC_Helicopter_Flights_Externality_Costs.xls) with assumptions, calculations and citations supporting my preliminary $2,500 per-flight noise cost estimate, my tax revenue estimate of $10 to $15 million, and other figures in my testimony may be downloaded via this link: https://www.komanoff.net/jet_skis/NYC_Helicopter_Flights_Externality_Costs.xlsx.

Carbon Footprint

Want a simpler way to buy carbon credits? Discover our carbon marketplace

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Most businesses that decide to act on their net-zero targets reach the same point of friction. Buying carbon credits has meant tracking down brokers, sitting through sales calls, and requesting a quote just to learn a price, sometimes with limited proof of what you are buying.

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Climate-Linked Supply Chain Risk Is Already in Your P&L

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The earnings calls that quietly reframed climate from sustainability question to operating risk.

Three earnings calls in the last 18 months tell the story without any help from a press release.

Hershey, May 2024: cocoa price exposure compresses margin, and the company attributes part of the cost shock to West African weather. Olam, July 2024: coffee climate exposure quantified in the annual report. JBS, January 2025: supply chain climate disclosures expanded materially in response to investor pressure and regulatory expectation. None of these companies issued the announcement as climate news. They issued it as financial news. The climate-linked supply chain risk did not arrive with a sustainability framing; it arrived as a P&L line.

You are probably reading this article because you suspect the same thing is happening to your business. This piece walks through what is showing up on which earnings calls, how procurement and finance leaders are quantifying the exposure, and what serious corporates are doing about it before the regulator asks.

Where climate risk has already appeared in earnings

The pattern is consistent across resource-intensive sectors. A weather event compresses supply, the price spikes, the cost flows through the income statement, and the analyst on the call asks whether the event is anomalous or structural. Increasingly, the honest answer is the second one.

Cocoa is the cleanest example. The 2023 to 2024 West African harvest fell sharply on the back of erratic rainfall and disease. Cocoa futures more than tripled. Companies with concentrated West African sourcing absorbed the cost; companies with diversified sourcing absorbed less. The exposure was not climate as ESG topic. It was climate as cost of goods.

Coffee follows the same pattern. Brazilian and Vietnamese harvests have moved on weather more sharply across the last several seasons. Roasters with long-tenor supplier relationships and origin diversification have managed the volatility; roasters with spot-market exposure have not. Wheat, sugar, palm oil, beef: the same dynamic in different commodities, a pattern the IPCC AR6 Working Group II report projects will intensify across agricultural systems through mid-century.

What this means: climate risk is no longer a footnote in the 10-K. It is a line item the CFO has to explain on the call.

The three commodity exposures that hit margin first

For most companies with material Scope 3 exposure, three exposures dominate the near-term P&L risk.

  • Concentrated single-origin sourcing in a climate-vulnerable region. If your tier-one supply for any material commodity sits in one geography, you have a concentration risk that climate amplifies. Diversification across origins is the obvious hedge, but it takes years to build and requires relationships you cannot acquire by tender.
  • Supplier financial fragility under climate stress. Smallholder farmers, who supply a large share of the global cocoa, coffee, and palm oil market, do not carry the balance sheets to absorb yield shocks. When yields collapse, they exit. When they exit, your supply base shrinks, and the surviving suppliers raise prices. The risk is structural, not cyclical.
  • Logistics and storage exposure to extreme weather. Hurricane disruptions to Gulf shipping, drought-driven Panama Canal restrictions, flooding in European inland waterways: each of these has moved input costs in the last three years, a pattern documented in Munich Re’s natural catastrophe data. The exposure shows up as a one-quarter event in the financial press but accumulates over time on the cost line.

TCFD and ISSB disclosure changes

The disclosure architecture has now caught up with the risk. The Task Force on Climate-related Financial Disclosures, whose recommendations are now embedded in the ISSB’s IFRS S2 climate standard, requires companies to disclose climate-related risks across physical and transition categories, with quantification where possible.

For physical risk specifically (the climate-linked supply chain risk you are reading about), the disclosure must address both acute exposures (extreme weather events) and chronic exposures (gradual changes in temperature, precipitation, and growing seasons). The disclosure must address the time horizon over which the risk is material, the parts of the value chain exposed, and the financial impact under different scenarios.

The CSRD imposes similar requirements under European law, with double materiality (both financial and impact materiality) embedded in the assessment. The practical effect: your auditors and your investor relations team now need a defensible answer to the climate-linked supply chain risk question, and the answer needs to be quantified.

What procurement and finance can do now

Three actions matter near-term.

Map your exposure. Most companies do not have a clear view of which tier-one and tier-two suppliers sit in which climate-vulnerable geographies. Without the map, you cannot quantify the risk, and without the quantification, you cannot disclose it credibly. The map is the foundation, and World Resources Institute climate risk research provides useful public tooling to start.

Diversify and deepen, in that order. Diversification across origins reduces concentration risk, but the deeper move is to invest in the resilience of the suppliers you already have. Regenerative practices, agroforestry, soil health interventions: these reduce yield volatility under climate stress and protect your input cost trajectory.

Embed the climate spend inside procurement, not outside it. Treating climate risk as a sustainability cost line subordinates it to the ESG budget. Treating it as a procurement and resilience investment puts it in the budget that matters, which is the cost-of-goods budget that the CFO defends quarterly.

Nature-based supply chain investments are the asset class designed for exactly this purpose. They sit inside the value chain, they reduce climate-linked supply risk, they generate verifiable Scope 3 reductions, and they produce the documentation an auditor and a regulator can both test.

If you are quantifying climate-linked supply chain risk in advance of the next earnings cycle or the next disclosure period, the carbon and sustainability experts at Carbon Credit Capital can help you map your exposure and structure a Dual-Value Model response that addresses reduction, resilience, and disclosure-readiness in a single program. Schedule a consultation.

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Carbon Footprint

Where should an SME start with a carbon action plan?

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More and more small and medium-sized businesses are hearing the same question from their larger customers: What is your carbon footprint? That question now travels down entire supply chains, and it arrives next to tender requirements, certification criteria, and rising customer expectations.

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