Tue 18 Sept 2018 – International airline associations have written a joint open letter to the European Commission urging it to ensure the ICAO proposed rules governing the CORSIA carbon offsetting scheme are adopted uniformly and in their entirety throughout Europe. They also call for the monitoring, reporting and verification (MRV) requirements of the EU ETS to be aligned with those of CORSIA in order to avoid an added administrative burden, and for all international intra-EEA flights to be removed from the scope of the EU ETS from January 2021 when the first voluntary phase of CORSIA starts. In response, a group of Europe-based NGOs has called on the Commission to resist any moves to amend, barring certain non-essential MRV provisions, the EU ETS directive and for the EU to reserve its position on CORSIA until a review of the ICAO scheme has taken place.
The letter from 10 European and non-European airline associations plus IATA says it is fundamental that the international standards and recommended practices (SARPs) for CORSIA, which have been adopted by the ICAO Council as a new Volume IV of Annex 16 to the Chicago Convention, are similarly adopted and implemented by Europe in full and for all international flights that are subject to CORSIA. If CORSIA and EU ETS MRV requirements were not aligned, they say, operators and authorities would have to comply and administer two schemes and two sets of rules in parallel.
“The SARPs have been the fruit of several years of technical work in ICAO and are just as robust as the EU ETS MRV,” maintain the associations.
The industry argues that with the implementation of CORSIA’s pilot phase from 1 January 2021, there is no further need for the EU ETS to apply to emissions from international flights between airports in the European Economic Area from this date. They point to the A39-2 resolution adopted by the ICAO Assembly in 2016 that states market-based measures should not be duplicative and international aviation CO2 emissions be accounted for only once.
“If the EU were to attempt to exclude international intra-EEA flights from the application of CORSIA or subject international flights to both EU ETS and CORSIA, this would set a very damaging precedent, incurring ineffective and costly duplications and compromising the implementation of CORSIA,” they say.
The letter concludes: “Our associations and the broader airline industry are fully committed to CORSIA and we are now in a crucial period of preparation for CORSIA’s implementation. We believe European States should continue to play a key role in addressing aviation’s emissions by being amongst the first to implement Annex 16, Volume IV, without differences.
“We therefore hope we can count on your commitment to ensure European States meet their commitments under the Chicago Convention and implement Annex 16, Volume IV in its entirety from 1 January 2019.”
The three NGOs – Transport & Environment, Aviation Environment Federation and Carbon Market Watch, which are members of the ICSA NGO alliance recognised by ICAO – say the proposed SARPs still await the views of ICAO Member States, which have until October 22 for an initial response and December 1 to notify ICAO of any differences to be filed. The Commission is expected to propose a common position for EU/EEA States to take.
The NGOs urge the Commission to delay a response to ICAO about the proposed SARP rules and voluntary participation in CORSIA until the completion of a review they say is mandated under the EU regulation adopted by the Council and Parliament in December 2017 amending the directive (2003/87/EC) covering the EU ETS and aviation.
“Any reply proposed by the Commission should reserve European and Member State positions through filing a general difference to protect Europe’s right to meet its legal obligations under international law, in particular the Paris Agreement,” says the NGO’s letter.
“Given CORSIA’s unresolved issues, its environmental weakness and lack of alignment with European climate ambition, industry calls to replace the EU ETS are premature and must be rejected.
“A requirement to replace the EU ETS, with its more ambitious target and reliance on allowances, with CORSIA, which has a weaker target and relies on offsets of as yet unknown quality and which count for zero towards climate targets under EU law, would itself constitute a breach of the Paris Agreement’s ‘no backsliding’ provision in Article 3.”
States have until 30 June 2020 to notify ICAO of their intention to participate in the first voluntary phase and the NGOs say no decision should be made by Europe until the mandated review has taken place. “There is the option to volunteer all flights or none, or just flights to and from Europe, thus excluding flights between EU States,” they add.
The 2017 amendment to the directive extended the derogation from the EU ETS obligations for flights to and from third countries until 31 December 2023, “subject to review, to allow the experience necessary for the implementation of the ICAO scheme to be gathered.”
In response to an ICAO consultation earlier in the year on the draft SARPs, European countries backed the implementation of the CORSIA ‘package’ but warned against attempts by others to water down the environmental ambition of the scheme in relation to the quality of eligible emission units used to offset emissions and the sustainability of alternative fuels claimed for emission reductions.
“We are willing to contribute to a global compromise, but not with a lower environmental integrity than proposed,” responded one European country to the consultation.
Letter from airline associations (AFRAA, AASA, A4A, A4E, AIRE, AACO, AAPA, ALTA EEA, ERA, IATA)
Letter from NGOs (AEF, CMW, T&E)
Editor’s note: The impact of CORSIA on the Aviation EU ETS will be discussed by representatives from the airline industry, NGOs and the European Commission in a panel session at the Aviation Carbon 2018 conference in London on November 5. The event is co-organised by GreenAir Online. Details here.
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