Eurocontrol's Emissions Trading Scheme Workshop
Tue 3 Mar 2009 – A workshop has been hosted by Eurocontrol to address concerns by aircraft operators over the administrative costs they are likely to face as a result of the monitoring, reporting and verification (MRV) of emissions required by the EU directive incorporating aviation into the EU Emissions Trading Scheme for flights arriving or departing the EU from 2012. Airline representatives also called for the compliance process to avoid complexity and for the exchange of traffic and emissions data to remain confidential.
The Director General of Eurocontrol, David McMillan, said aviation’s impact on the environment generated strong public, media and political opinion, and he was aware of the “fever pitch of controversy” which the ‘European approach’, especially on the issue of emissions trading schemes, had generated.
“We are also sensitive to the growing importance of environment within our industry, fully aware of what is at stake at the forthcoming UNFCCC Conference of the Parties in Copenhagen in December,” he told delegates from aircraft operators, regulators, industry, States and the European Commission. “The second package of Single European Sky legislation, the environmental objectives of SESAR, and now the inclusion of aviation activities in the ETS show just how much environmental considerations now permeate our industry.”
He said the implementation of the ETS will inevitably introduce additional tasks and investments for everybody involved, just as the global financial crisis was severely affecting the industry worldwide and challenging the availability and release of resources. “So I put it to you that the early establishment of lean mechanisms in support of the whole process is essential to achieve the most efficient and effective scheme possible, minimizing as far as possible the overhead of compliance costs.”
“As for the European Commission,” he went on, “they need to be confident that it is working effectively to track progress against the Community’s ambitious emissions reduction goals. But we also acknowledge that the States – as still our political masters – need to know how they can efficiently regulate a scheme for a sector in which installations are mobile, not fixed. A sector in which ownership of the installations can change hands quite rapidly, with various means of providing a service to the passenger. A sector where installations will operate outside the national boundaries of the administering State, often even for the entirety of a flight.”
McMillan said the pan-European data, including environmental data, held by Eurocontrol would prove very useful in keeping track of these factors as it was gathered to support air traffic performance analysis and improvement and it applied to every single flight in the system.
Participants at the workshop called on Eurocontrol to make this information available to support stakeholders in complying with the monitoring, reporting and verification process.
Olaf Hoelzer-Schopohl from the German Emissions Trading Authority at the Federal Environment Agency – the ‘competent authority’ responsible for administering the ETS in Germany – suggested that if experience over the short term proved that emission estimates by Eurocontrol data did not differ significantly from what was reported by aircaft operators then those operators who wished it could be released from the burden of submitting verified emission reports based on real fuel consumption.
“This would constitute a drastic difference to the stationary installations, but would allow for an ETS with very low transaction costs,” he said.
Andreas Hardeman of the International Air Transport Association laid out some key principles airlines wished to see in the MRV compliance process: use existing industry practices, don’t reinvent the wheel, keep it simple, don’t require more than what’s strictly needed for compliance, equal treatment and don’t let MRV become a competitive issue. He said operators urgently needed a final MRV guidance document.
Operators, he continued, also required clarity on contact points within the competent authorities, dates for meetings and workshops, charging practices and guarantees on data confidentiality. There was also a need for the publication of a list of experienced and accredited verifiers who should have aviation expertise and training to ensure aviation-specific working knowledge.
Delphine Dantec of Air France echoed the need to keep the MRV process simple and to avoid unnecessary complexity to suit a quick implementation. She said there were a number of challenges facing airlines, including airline-specific adaptation of the ETS guidelines, fuel consumption and emissions calculation methods, as well as the growing delay in the regulation process, with just three months to write the monitoring plan.
Brian Humphries, President of the European Business Aviation Association, said the administration of the ETS across several thousand business aircraft operators in Europe would be very expensive and administratively difficult to all parties. He stated the complex MRV methodology being developed for airlines was intended for large emitters and was wholly inappropriate for the de minimis emitters which comprise the bulk of business aviation operators.
He therefore proposed a simplified MRV for small aircraft based on Eurocontrol data that has been independently verified.
Humphries warned that allowing offshore operators to have simpler procedures than home-based companies would seriously distort competition against European operators and damage the EU industrial base.
Chris Dekkers, EU ETS Compliance Forum Coordinator, said it was important that all stakeholders – competent authorities, verifiers and aircraft operators – work together in a cooperative spirit with a clear understanding of each other’s issues, interests and concerns to find workable solutions, as “full compliance was in everybody’s interest”.
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