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.
Nature-based carbon investments deserve consideration when they address a specific business dependency and produce outcomes you can measure. Imagine Moonbucks, a global coffee roaster planning next season’s espresso blend. It is considering natural Grade 4 coffee from Jimma, in southwestern Oromia, Ethiopia. Its sourcing decisions affect the roasting schedule and the cash tied up in coffee purchases. Moonbucks needs to understand which measures could protect that supply, what they would cost and how it would judge the results.
1. Define the sourcing problem before choosing a project
Moonbucks needs a dependable component for its espresso blend. Its procurement team wants continuity of volume and an agreed cup profile. Replacing a shipment at short notice could require new sample approval and changes to the blend, and given the schedules for cultivation, processing, and freight delivery, is practically impossible. Moonbucks needs to get this right, and its initial concern is inconsistent deliveries. It commissions an assessment of the supplying farms and post-harvest chain. The questions cover land condition, harvest availability and whether drying or storage problems are affecting saleable lots.
This distinction changes the investment brief. A tree-planting proposal cannot be assumed to fix drying problems. Better storage cannot restore eroded land. The team must establish which problem exists before selecting the response.
CCC’s guide to finding nature-based solutions in your supply chain explains where to look. Here, the next task is to turn a broad concern into a testable proposal.
2. Develop nature-based carbon investments around the actual supply chain
The assessment would trace Moonbucks’ purchases back through the exporter and supplying producer groups. Which farms supply the contracted lots? Who controls land-management decisions? How long does the buyer expect to maintain the purchasing relationship?
Furthermore, Jimma natural Grade 4 cannot be treated as interchangeable with every Ethiopian coffee. Moonbucks would need to test any substitute against its own blend and quality requirements.
Suppose Moonbucks’ assessment identifies an opportunity to maintain shade trees and restore vegetation along exposed streambanks. The IPCC describes agroforestry as a way to store carbon in vegetation and soil, with potential benefits for erosion control and water quality.1 Moonbucks would need local advice on species, growing conditions and maintenance before deciding how these measures fit its sourcing plan.
The proposal now has a defined sourcing connection and a candidate intervention. The next steps are to test its effect on production, assess carbon eligibility and build the financial case.
3. Compare the proposal with other ways to protect supply
WBCSD’s Nature-based Solutions Blueprint recommends comparing nature-based options with other responses across their benefits and costs.2 For Moonbucks, that means evaluating the landscape proposal alongside drying improvements, storage controls and alternative sourcing arrangements.
The product’s natural-process designation matters. Moonbucks should examine the drying and dry-milling chain alongside land conditions. Its team would check storage practices, contamination risks and incoming-lot quality to see whether problems arise before or after the coffee leaves the farms.
The revised proposal might combine land stewardship with separate post-harvest controls. Each component needs its own purpose and budget. A sustainability label should not obscure which activity is expected to solve which problem.
The project develops as the evidence improves. Its scope should follow the diagnosis rather than preserve the first idea unchanged.
4. Establish what the carbon outcome could count toward
Moonbucks’ sustainability team now tests the proposed carbon case separately from the sourcing case. Is the objective a measurable change in Moonbucks’ value-chain emissions, verified credits for separate voluntary use, or distinct outcomes under carefully defined arrangements?
Scope 3 covers value-chain emissions. A purchasing relationship alone does not prove that a farm intervention can be included in Moonbucks’ inventory. The team needs an applicable accounting method, defensible boundaries and evidence supporting attribution.
SBTi’s FLAG Guidance (forest, land and agriculture), version 1.2, says purchased credits used as offsets cannot meet near-term FLAG or energy and industry targets. Eligible land-based removals are subject to accounting requirements.3 Moonbucks needs to test its proposal against those rules before including an outcome in its targets.
For Moonbucks’ Jimma proposal, maintaining existing trees and establishing new vegetation could involve different carbon questions. Specialists must examine the baseline and additionality, meaning what changes because the project proceeds. They must also assess measurement and the risk that stored carbon is lost. CCC’s MRV and additionality article introduces those tests.
Until that work is complete, Moonbucks should not budget an assumed Scope 3 reduction or credit-sale receipt. Direct emissions reductions remain the priority.
5. Build a financial case that survives weaker assumptions
Moonbucks’ finance team would now build a multi-year budget. UNEP’s State of Finance for Nature 2023 compares current finance with the investment needed to meet climate, biodiversity and land-restoration goals.4 The company would cost its proposed activities, farmer participation and ongoing monitoring. Verification, where required, is a separate expense. Maintenance and responsibility for replacing failed plantings must remain visible after the initial establishment budget ends.
Operational benefits need equally careful treatment. If fewer rejected lots reduce emergency purchasing, count that saving once. Do not add “supply resilience” as another financial benefit when it represents the same avoided cost.
Moonbucks should compare a base case with slower benefits, higher implementation costs and no carbon revenue. It should also distinguish production outcomes from quality and shipment outcomes. A single good harvest would not prove that the landscape intervention caused better delivery performance.
A project can remain worth funding even when its carbon case needs more work. That decision must rest on the operational evidence and the company’s objectives, without unsupported environmental claims.
6. Fund a pilot with a clear expansion decision
Moonbucks’ first approval would fund a bounded pilot, rather than commit the entire sourcing program. Before spending, Moonbucks would agree on participating farms, responsibilities and the evidence needed at review.
Its scorecard could track farmer participation, implementation costs and plant survival, alongside accepted coffee volumes and lot-quality results. Carbon measurements would follow the selected method. Farm-level traceability must connect the intervention to the actual sourcing relationship.
Suppose Moonbucks’ review later finds that storage changes explain most quality improvements, while the land measures need longer observation. Those findings would shape the next decision: expand the proven component, adjust the landscape work or pause further spending. They would not justify crediting all improvements to tree planting.
This gives nature-based carbon investments a practical place in a multi-year strategy. Funding increases as the evidence supports it, and the project can change direction before a larger commitment.
Discuss a sourcing opportunity with CCC
Carbon Credit Capital’s nature-based supply-chain investment service uses its Dual-Value Model to examine supply-chain economics alongside potential sustainability outcomes.
Schedule a consultation to discuss your sourcing exposure and the questions to resolve before allocating capital.
Sources
- Intergovernmental Panel on Climate Change (IPCC), Climate Change 2022: Mitigation of Climate Change, Chapter 7, Agriculture, Forestry and Other Land Uses, section 7.4.3.3 (Agroforestry).
- World Business Council for Sustainable Development (WBCSD), Nature-based Solutions Blueprint, 5 June 2024.
- Science Based Targets initiative (SBTi), Forest, Land and Agriculture Science-Based Target-Setting Guidance, version 1.2, March 2026, section 3.1.4, pp. 37–38.
- United Nations Environment Programme (UNEP), State of Finance for Nature 2023, 2023.
A plastic credit funds the collection of plastic waste in places where no formal system exists to collect it. Each credit represents a measured, independently audited quantity of plastic taken out of the environment or returned to use, tracked on a public registry.
EU carbon credit claims changed on 27 September 2026, the day the Directive (EU) 2024/825 began to apply across the European Union. The change is narrow. It changes how a company can talk about the credits it buys. A product can no longer be called neutral on the strength of compensation alone; however, every specific, evidenced statement about what a company measured, reduced, and funded stays fully available.
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