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.
The accounting differences that decide whether your nature investment shows up in inventory, in BVCM, or nowhere at all.
The question reaches a procurement team about three weeks before the next sustainability committee meeting. Someone has read about insetting. Someone else has just signed off on an offset purchase. The CSO wants to know if the two are interchangeable. The answer is no, and the GHG Protocol Land Sector and Removals Standard is the reason why.
This article walks through what each term means at audit-grade specificity, what the standards actually say about how each gets counted, and how to decide which tool fits which target. The insetting vs offsetting question is one of the most-searched in corporate climate strategy, and one of the most poorly answered. By the end of this piece, you should be able to brief a committee on the difference without notes.
The two definitions, in plain English
Offsetting means buying carbon credits generated outside your value chain and retiring them against your residual emissions. The reduction happens somewhere else, financed by you, and the credit is the receipt.
Insetting means investing in emission reductions or removals inside your own value chain, typically with suppliers, where the reduction is directly linked to the products and services you buy. The reduction happens inside the boundary of your Scope 3 inventory, and the accounting treatment is fundamentally different.
The shorthand from the University of Oxford’s Nature-based Insetting Initiative is useful: insetting is what you do with the supply chain you have; offsetting is what you do with the supply chain you do not have.
What the GHG Protocol Land Sector Standard actually says
The GHG Protocol Land Sector and Removals Standard, finalised in 2024 after a multi-year pilot, sets the rules for how land-based emission reductions and removals enter corporate inventories. The Standard distinguishes between inventory accounting (Scope 1, 2, and 3) and project or intervention accounting (a separate methodology for crediting).
For insetting, the practical implication is that supplier-level interventions, when properly measured and attributed, can reduce your Scope 3 category 1 (purchased goods and services) emissions in your inventory. The reduction is not a credit retired against the inventory; it is a lower inventory number, period.
For offsetting, the credit is retired separately. It can be reported as a contribution toward a net-zero claim under the SBTi Beyond Value Chain Mitigation framework or as part of a VCMI Carbon Integrity claim, but it does not lower the inventory number.
A practical consequence: if your Science Based Target requires a 50% absolute reduction in Scope 3 emissions by 2030, insetting moves you toward the target. Offsetting does not. This single point of difference reshapes the procurement decision.
When insetting counts toward Scope 3 (and when it does not)
Insetting counts toward Scope 3 only when several conditions are met:
- The intervention must occur with an entity in your value chain.
- The emissions reduction or removal must be measured against a defensible baseline.
- The reduction must be attributed to your share of that supplier’s output, not double-counted with other buyers.
- It must follow the inventory accounting rules in the GHG Protocol Land Sector Standard, not the project accounting rules used to generate credits.
The most common failure mode is double counting. If your supplier sells the same reduction as a credit on the voluntary market and also reports it to you as a Scope 3 reduction, the math breaks. The Standard requires you to address this risk, typically by purchasing and retiring the supplier-issued credit as part of your inventory or by contractual provisions that prevent the supplier from selling the reduction twice.
When insetting does not count toward Scope 3: when the intervention sits with a supplier you do not buy from, when the baseline is not defensible, when the attribution is unclear, or when the documentation does not survive audit. Those cases default to Beyond Value Chain Mitigation, which is still useful but operates on a different ledger.
The procurement and supplier engagement question
Insetting is harder than offsetting. That is the unfashionable truth most buyers eventually confront. Offsetting is a transaction; insetting is a relationship.
To run an insetting program, you need supplier mapping precise enough to know which farms or facilities sit at which Scope 3 boundary. You need an engagement model that gets suppliers to participate, which usually requires multi-year commitments and shared economics. You need an MRV architecture that measures the right things and produces audit-ready documentation. And you need a contractual structure that prevents double counting and protects both sides.
The trade-off you receive in return is significant. Reductions count against your inventory rather than your residual. Supplier relationships deepen, which protects sourcing continuity. Yield and quality improvements often follow regenerative interventions, which reduces your input cost over time. And the regulatory file, under CSRD, CSDDD, EUDR, and the SBTi FLAG Guidance, is materially stronger.
Choosing the right tool for the right target
A practical decision rule. If your target is a science-based Scope 3 reduction and you operate in a FLAG sector or source FLAG commodities, insetting is the structurally correct tool. If your target is a net-zero claim that includes neutralising hard-to-abate residual emissions outside your value chain, BVCM via high-integrity offsets is the structurally correct tool. Most companies with material Scope 3 exposure need both, in different proportions, sequenced over time.
The sequencing matters. Insetting takes longer to stand up but produces a permanent reduction in the inventory. Offsetting can be transacted faster but does not change the inventory and now sits under tighter claim restrictions. Treat them as complementary tools with different jobs, not as substitutes. The Accountability Framework Initiative and the IUCN Global Standard for Nature-based Solutions both provide useful guardrails for the insetting side, with biodiversity, human rights, and benefit-sharing requirements that go beyond carbon math.
If you are mapping a Scope 3 reduction roadmap and need to scope which interventions count toward your inventory versus which sit in Beyond Value Chain Mitigation, the carbon and sustainability experts at Carbon Credit Capital can help you structure a nature-based supply chain investment program that fits your FLAG exposure, your target architecture, and your audit horizon. Schedule a consultation.
Net zero is often described as a balancing act: cut what you can, account for the rest, and reach zero on the ledger. That framing is useful, but it leaves something out. It treats every tonne of carbon as interchangeable and every route to zero as equally sound, while the science tells a more specific story.
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