European Commission opens consultation on international aviation MBM policy options ahead of ICAO Assembly
Fri 28 June 2013 – The European Commission has opened a consultation seeking opinions and suggestions on various policy options concerning international aviation market-based measures ahead of the ICAO Assembly that starts late September. The Commission is requesting input from relevant aviation and climate change stakeholders and experts on the two workstreams taking place at ICAO on developing a framework for the application of national or regional MBMs and a single global MBM. Specifically, the Commission is looking for views on the various geographical scope options under the framework, the roadmap it has proposed towards implementing a global MBM, and requirements for the monitoring, reporting and verification (MRV) of international aviation emissions. The consultation is also asking for views on how the EU ETS compliance and administrative burden on non-commercial small aircraft operators could be reduced.
In the consultation document, the Commission lays out its reasoning behind the inclusion of international aviation carbon emissions into the EU Emissions Trading System ( EU ETS) and the year-long derogation of intercontinental flights from the scheme agreed by the EU to allow progress towards a “meaningful outcome” on MBMs at the 2013 Assembly.
Since the ‘stop the clock’ proposal was announced last November following an ICAO Council meeting that agreed the setting up of a high-level group, the HGCC, to accelerate progress on the workstreams, the Commission feels that as the discussions have taken place behind closed doors at ICAO, it would be useful to gather feedback from a wider group of stakeholders on the policy options under consideration in the lead up to the Assembly.
The Commission has used the consultation to lay out its own proposals and position on the framework and the global MBM, and has put into the public domain two ICAO working papers the EU presented at a HGCC meeting in March. A number of these proposals have met with opposition from other states on the governing ICAO Council, particularly concerning the geographic scope of the application of an MBM by a country or region under the framework. The intention of the framework is to provide a guiding set of common principles that states or regions must adopt when designing and implementing their own MBM before a single global MBM for international aviation may come into force.
Under the EU ETS directive, the total CO2 emissions of all flights to, from and within EU and EEA states are covered. Although the EU is willing to exclude intercontinental incoming flights as part of an ICAO agreement, it is concerned about a current proposal favoured by some leading states at ICAO, including the United States, to restrict coverage to arriving and departing flights within national airspace to deal with the controversial issue of sovereignty. If the airspace proposal – which is opposed by industry as well because of the administrative complexity involved – was adopted then only a maximum 22% of international aviation emissions would be covered, even if all states implemented similar measures, according to expert analysis submitted by the EU.
“In the absence of a global MBM, or pending its implementation, the reliance on a geographic scope approach that involves only a small portion of international aviation emissions being covered by MBMs would raise serious questions as to how the global goals can be met,” concluded the EU paper to the HGCC.
The consultation asks stakeholders for their opinions on what should be the major considerations when assessing the four different geographical scope options put forward at ICAO.
The EU has come to accept that a binding agreement on a single global MBM scheme is unlikely to be forthcoming at this year’s Assembly but is looking for a roadmap to be adopted with clear elements for the design of a scheme and a timetable for its introduction to be completed by the following Assembly in 2016.
In parallel, says the consultation document, the ICAO Council should develop, “as a matter of priority”, a common set of monitoring, reporting and verification standards for measuring greenhouse gas emissions from international aviation.
The consultation invites stakeholders to assess the various elements contained in the roadmap in terms of importance and express an opinion on the optimal timeline for implementation of the global scheme. They are also asked to comment on what they consider to be the essential requirements of a MRV standard.
The Commission has taken the opportunity to also consult with stakeholders on the inclusion of non-commercial aircraft operators, so-called small emitters, within the EU ETS. Under present de minimis rules, commercial operators that operate less than 243 flights per three consecutive periods of four months, or emit less than 10,000 tonnes of CO2 annually, are exempted from the EU ETS provisions.
Although many small emitters – there is a 25,000 tonne threshold – can take advantage of simplified procedures to monitor their emissions, they are disadvantaged by the disproportionate administrative and financial burden of compliance over relatively small amounts of CO2 emissions.
On behalf of the Commission, consultancy PwC is currently already looking at the issue but the questions asked in this new consultation are aimed at complementing the PwC work, and seeks wider views on what actions would help decrease the compliance costs for small non-commercial operators and whether a de minimis exemption, and at what threshold, should also be applied to them.
The consultation, which is open to both EU and non-EU stakeholders, runs until 13 September 2013 and the Commission says it intends for responses to be made publicly available on its website.