Aviation and the EU Emissions Trading Scheme
The Kyoto Protocol adopted in Kyoto, Japan, on 11 December 1997, excluded emissions from international aviation services from national emissions targets, and stipulated that an approach to addressing emissions from international aviation should be developed separately through the International Civil Aviation Organization (ICAO). Owing to a lack of consensus over whether and how to allocate responsibility for these emissions, only domestic CO2 emissions are included in the Kyoto Parties’ national emission totals. Emissions from international flights are not subject to the quantified emissions limitations taken on by the countries which ratified the Kyoto Protocol.
The European Commission proposed in February 2005 that international aviation should be included in any post-2012 climate change regime. A new directive 2008/101/EC of the European Parliament and of the Council of the European Union requires all aircraft operators flying into or out of any EU airport to participate in the EU’s emissions trading scheme (ETS) from 2012.
The EU's emissions trading scheme could be a model for a global scheme as the International Civil Aviation Organisation is developing a framework for a global emissions trading scheme for aviation as part of an attempt by the ICAO to retain responsibility for the environmental impact of aviation under a post-2012 international agreement that will have to be agreed in Copenhagen in December 2009.
The European Greenhouse Gas Emissions Trading Scheme has been operational since January 2005 for some 12 000 installations in the 27 Member States ranging from oil refineries and power plants to cement, iron and ceramic production facilities. Emissions from these sectors account for nearly 40 % of the European Union total greenhouse gas emissions.
The scheme is based on Directive 2003/87/EC, which entered into force on 25 October 2003. Emission trading is an economic policy instrument used to control emissions by providing economic incentives for achieving emission reductions. An emission trading system sets a cap on the amount of a pollutant that can be emitted.
Companies under the trading system are given allowances which represent the right to emit a specific amount. Companies that emit in excess of their allowances must buy allowances from an operator that has more allowances than it needs. In the first period, 15% of allowances are to be auctioned.
For the period from 1 January 2012 to 31 December 2012, the total quantity of allowances to be allocated to aircraft operators will be equivalent to 97% of the mean average of the annual emissions in the calendar years 2004, 2005 and 2006. For the eight year period beginning on 1 January 2013 the total quantity will be equivalent to 95 % of historic aviation emissions.
Categories of activities included in the EU ETS.
Aircraft operators may apply for an allocation of allowances that are to be allocated free of charge (82% of emission allowances will be allocated for free in 2012). An application may be made by submitting to the competent authority in the administering Member State verified tonne-kilometre data for the aviation activities.
A special reserve of free allowances is being provided for new entrants and fast growing airlines (3% of the total quantity of allowances). 15% of allowances are to be auctioned in 2012.
From 1 January 2012 all flights which arrive at or depart from an airport situated in the territory of a Member State to which the Treaty applies shall be included in the EU ETS.
A ‘flight’ is the operation of an aircraft from the moment the aircraft first moves under its own power (block-off) for the purpose of taking off until the moment it comes to rest after landing (block-on).
Not included are categories such as military flights, customs and police flights, flights related to search and rescue, fire fighting flights, humanitarian flights, flights performed exclusively under visual flight, training flights, flights performed by aircraft with a certified maximum take-off mass of less than 5 700 kg and flights performed in the framework of public service obligations on routes within outermost regions or on routes where the capacity offered does not exceed 30 000 seats per year.
Aircraft operators operating fewer than 243 flights per period for three consecutive four-month periods and aircraft operators operating flights with total annual emissions lower than 10 000 tonnes CO2 per year may estimate the fuel consumption using tools implemented by Eurocontrol. Eurocontrol is currently performing a feasibility study for an ETS support facility. Whereas this facility would reuse part of the PAGODA processes, some changes are required to them in order to meet the ETS directive prescriptions. The decision on the deployment of this facility will be based on the outcome of the feasibility study.
An aircraft operator making use of the simplified procedure and exceeding the threshold for small emitters during a reporting year shall notify this fact to the competent authority. Unless the aircraft operator demonstrates to the satisfaction of the competent authority, that the threshold will not be exceeded again from the following reporting period onwards, the aircraft operator shall update the monitoring plan to meet the monitoring requirements. The revised monitoring plan shall be submitted without undue delay to the competent authority for approval.
General rules of the Emission trading system
The allocation methodology for the distribution of allowances to aircraft operators will be based on the verified tonne-kilometre data and the total quantity of allowances for the air transport sector at the European level.
The annual issuance of allowances to operators must take place before March of each year. So an aircraft operator will receive the allowances for the year 2012 before March of that same year.
Each operator under the EU ETS has to have a greenhouse gas permit before it can operate. This permit is the monitoring plan. This plan lays down the rules that have to be followed when reporting the CO2 emissions data under the EU ETS. Each year, before April, the aircraft operator has to report the amount of CO2 emissions that have been emitted in the previous year. This report has to comply with the rules of the monitoring plan and has to be verified by an accredited verifier appointed by the operator. Most Competent Authorities will not publish a list of accredited verification bodies for the aviation sector before early 2010. Aircraft operators will therefore not be able to appoint an accredited verifier before this time.
Aircraft operators are obliged to match the (verified) emissions with an equal amount of allowances. This is called ‘surrendering’ of allowances. Each aircraft operator has to surrender the allowances (of the previous year) before May of the ongoing year. If an operator is short of allowances it will have to buy allowances from an installation or aircraft operator that has more allowances than needed to cover the verified emissions. A company that does not surrender enough allowances will be fined and will still be obliged to surrender the missing allowances.
Member States can allow a limited use of credits by the Clean Development Mechanism (CDM) and Joint implementation (JI) for compliance use in the EU ETS. This means that airline operators can use CERs (Certified Emission Reductions) and ERUs (Emission Reduction Units) next to EUAs (EU Allowances) to cover their emissions.
The Commission shall publish in February 2009 a list of aircraft operators which carried out aviation activity on or after 1 January 2006 specifying the administering Member State for each aircraft operator and before 1 February of each subsequent year, update the list to include aircraft operators which have subsequently carried out aviation activity. Route charges information available at EUROCONTROL’s CRCO has served as the principal source of data to identify the flights to which the Directive applies and the aircraft operator of such flights. (see Aircraft operator allocation by EC Member State process description)
In order to reduce the administrative burden on aircraft operators, one Member State will be responsible for each aircraft operator. Member States will be required to ensure that aircraft operators which were issued with an operating licence in that Member State, or aircraft operators without an operating licence or from third countries whose emissions in a base year are mostly attributable to that Member State, comply with the requirements of the EU ETS.
The administering Member State in respect of an aircraft operator shall be:
(a) in the case of an aircraft operator with a valid operating licence granted by a Member State, the Member State which granted the operating licence; and
(b) in all other cases, the Member State with the greatest estimated attributed aviation emissions from flights performed by that aircraft operator in the base year.
Each aircraft operator may apply for an allocation of allowances that are to be allocated free of charge by submitting to the Competent Authority verified tonne-kilometre data for the calendar year ending 24 months before the start of the period to which it relates or in relation to the period from 1 January 2012 to 31 December 2012, the year 2010.
How to comply with the ETS obligations
Aircraft operators need to have an emission permit and be registered in the register of the administering EU Member State and must have implemented the plans for monitoring and reporting.
CO2 emission rights and costs must be incorporated into the company's operational, financial and risk management system and emission rights will be shown on the balance sheet. A trading strategy for emission rights should be developed.
Aircraft operators have to submit following information to the respective competent authority:
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monitoring plan for the reporting of tonne-kilometre data;
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monitoring plan for the reporting of annual emissions;
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verified annual emissions report; and
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verified tonne-kilometre data.
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The competent authorities will publish in the first half of 2009 standardized templates that must be used by aircraft operators to report (a) the monitoring plan for tonne-kilometre data, (b) the monitoring plan for emissions, (c) tonne-kilometre data and (d) annual emissions. Competent authorities may use the standardized electronic templates developed by the Commission.
A monitoring plan for the reporting of tonne-kilometre data and a monitoring plan for the reporting of annual emissions must be submitted to the Competent Authority at least four months prior to the start of the first reporting period and for the first time before September 2009 (or earlier in some administering member states).
The use of official templates for the submission of both monitoring plans is compulsory.
The Competent Authority may contact the airline operator to discuss modifications to the monitoring plan to ensure the accurate and verifiable monitoring and reporting of data.
Once approved, the Competent Authority will send the Aircraft operator the approved Monitoring Plans. These plans will be used as the methodology for calculating tonne-kilometres and as the methodology for calculating Greenhouse gas emissions and will serve as a reference for verification of the tonne-kilometre report and for the emissions report.
All substantial changes in the operator’s monitoring methodology must be notified to the competent authority without undue delay.
Monitoring and reporting of emissions from aviation activities
Compliance with the Monitoring and Reporting Guidelines 2007 is needed for the submissions of annual emissions report.
(COMMISSION DECISION of 18 July 2007 establishing guidelines for the monitoring and reporting of greenhouse gas emissions pursuant to Directive 2003/87/EC of the European Parliament and of the Council (2007/589/EC). These guidelines will be amended by the Commission in 2009).
A verified annual emissions report must be submitted to the Competent Authority before April of each year and for the first time before April 2011. (or earlier in some administering member states).
A separate calculation should be made for each flight and for each fuel as well as aggregated emissions (tCO2) from all flights. Emissions should be monitored by calculation using the formula:
Fuel consumption x emission factor.
Fuel consumption shall include fuel consumed by the auxiliary power unit. Actual fuel consumption for each flight is to be used. If actual fuel consumption data is not available, a standardised tiered method should be used to estimate fuel consumption data based on best available information.
Monitoring of tonne-kilometre data
A verified tonne-kilometre report must be submitted to the Competent Authority before April 2011. Tonne-kilometre data has to be monitored and reported for the purpose of applying for an allocation of allowances. The amount of aviation activity shall be calculated in tonne-kilometres using the following formula: tonne-kilometres = distance x payload, where ‘distance’ means the great circle distance between the airport of departure and the airport of arrival plus an additional fixed factor of 95 km; and ‘payload’ means the total mass of freight, mail, passengers and baggage. Crew members are excluded.
Tonne-kilometre data will include:
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number of flights per airport pair;
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number of passenger-kilometres per airport pair;
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number of tonne-kilometres per airport pair;
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chosen method for calculation of mass for passengers and checked baggage; and
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total number of tonne-kilometres for all flights performed during the year.
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Verification of tonne-kilometre and emissions data
Airline operators have to appoint an accredited verifier for the tonne-kilometre report as well as for their annual emissions report to check the data underlying the annual report and conformance with the approved monitoring plan of their procedures for calculating tonne-kilometres and emissions. The verification process should address the reliability, credibility and accuracy of monitoring systems and the reported data and information relating to emissions.
The verifier shall in particular ascertain that only flights actually performed and falling within the ETS have been taken into account. In addition, the verifier shall ascertain that the payload reported by the aircraft operator corresponds to records on payloads kept by that operator for safety purposes.
To be able to show and ensure compliance and to be able to reconstruct emissions data reported, the operator shall keep records of all control activities and of the information for at least ten years after the submission of the annual emissions report.
For the purpose of identifying the unique aircraft operator, the call sign used for Air Traffic Control (ATC) purposes shall be used. The call sign is the ICAO designator in box 7 of the flight plan or, if not available, the registration marking of the aircraft. If the identity of the aircraft operator is not known, the owner of the aircraft shall be regarded as the aircraft operator unless it proves to the satisfaction of the competent authority who was the aircraft operator.
For the purpose of identifying the unique aircraft operator, the call sign used for Air Traffic Control (ATC) purposes shall be used. The call sign is the ICAO designator in box 7 of the flight plan or, if not available, the registration marking of the aircraft. If the identity of the aircraft operator is not known, the owner of the aircraft shall be regarded as the aircraft operator unless it proves to the satisfaction of the competent authority who was the aircraft operator.
Determination of CO2 Emissions
CO2 emissions from aviation activities shall be calculated using the formula:
CO2 emissions = Fuel consumption * emission factor
With
a) Fuel consumption
Fuel consumption is expressed as fuel consumed in mass units (tonnes) during the reporting period.
Fuel consumed shall be monitored for each flight and for each fuel and shall include fuel consumed by the auxiliary power unit . Actual fuel consumed shall be calculated using one of the following two methods:
METHOD A:
The following formula is used:
Actual fuel consumption for each flight (metric tonnes) = Amount of fuel contained in aircraft tanks once fuel uplift for the flight is complete (metric tonnes) – Amount of fuel contained in aircraft tanks once fuel uplift for subsequent flight is complete (metric tonnes) + Fuel uplift for that subsequent flight (metric tonnes)
METHOD B:
The following formula is used:
Actual fuel consumption for each flight (metric tonnes) = Amount of fuel remaining in aircraft tanks at engines shut down after the previous flight (metric tonnes) + Fuel uplift for the flight (metric tonnes) – Amount of fuel contained in tanks at engines shut down after the flight (metric tonnes)
b) Emission factor
Tier 1:
The following reference factors, expressed as t CO2/t fuel, based on the reference net calorific values and emission factors shall be used for each aviation fuel:
Emission factors for aviation fuels (tCO2/tfuel)
Aviation gasoline: 3.10
Jet gasoline: 3.10
Jet kerosine: 3.15
For alternative fuels for which no reference values have been defined, activity specific emission factors shall be determined.
c) Simplified procedures for small emitters
Aircraft operators operating fewer than 243 flights per period for three consecutive four-month periods and aircraft operators operating flights with total annual emissions lower than 10 000 tonnes CO2 per year shall be considered small emitters.
Small emitters may use simplified procedures to determine fuel consumption and annual emissions.
Fuel consumption of aircraft operators that are small emitters may be estimated using tools implemented by Eurocontrol or another relevant organisation, which can process all air traffic information available to Eurocontrol. The applicable tools shall be used only if they are approved by the Commission including the application of correction factors to compensate for any inaccuracies in the modelling methods.
Monitoring Plan
Aircraft operators shall submit their monitoring plan to the competent authority at least four months prior to the start of the first reporting period for approval.
The competent authority shall ensure that the aircraft operator reviews the monitoring plan before the start of each trading period and submits a revised monitoring plan as appropriate. After the submission of a monitoring plan for the reporting of emissions from 1 January 2010, a review of the monitoring plan shall take place before the start of the trading period starting in 2013.
The competent authority may require the aircraft operator to use an electronic template for submission of the monitoring plan. The Commission may publish a standardised electronic template or file format specification. In this case the competent authority shall accept the use by the aircraft operator of this template or specification, unless the competent authorities’ template requires at least the same data input.
Reporting Format
Aircraft operators shall use a standardised format for reporting their annual emissions. The competent authority may require the aircraft operator to use an electronic template for submission of the annual emission report. The Commission will publish a standardised electronic (Excel) template. In this case the competent authority shall accept the use by the aircraft operator of this template or specification, unless the competent authorities’ template requires at least the same data input.
Emissions shall be reported as rounded tonnes of CO2(for example 1 245 978 tonnes). Emission factors shall be rounded to include only significant digits both for emission calculations and reporting purposes. Fuel consumption per flight shall be used with all significant digits (e.g. 12 345.6 kilograms) for calculation.
Content of the annual emission report
Each aircraft operator shall include the following information in its annual emission report:
(1) data identifying the aircraft operator and the call sign or other unique designators used for air traffic control purposes, as well as relevant contact details;
(2) name and address of the verifier of the report;
(3) the reporting year;
(4) reference to and version number of the relevant approved monitoring plan;
(5) relevant changes in the operations and deviations from the approved monitoring plan during the reporting period;
(6) the aircraft registration numbers and types of aircraft used in the period covered by the report to perform the aviation activities covered by Annex I of Directive 2003/87/EC carried out by the aircraft operator;
(7) the total number of flights covered by the report;
(8) the data;
(9) Memo-Items: amount of biomass used as fuel during the reporting year (in tonnes or m³) listed per fuel type.
The monitoring plan
Aircraft operators shall submit their monitoring plan to the competent authority at least four months prior to the start of the first reporting period for approval.
The competent authority may require the aircraft operator to use an electronic template for submission of the monitoring plan. The Commission may publish a standardised electronic template or file format specification. In this case the competent authority shall accept the use by the aircraft operator of this template or specification, unless the competent authorities’ template is technically more advanced and requires the same data input.
Methodologies for calculating tonne-kilometre data
Calculation formula
Aircraft operators shall monitor and report tonne-kilometre data using a calculation-based methodology. Calculation of tonne-kilometre data shall be based on the following formula:
tonne kilometres (t km) = distance (km) * payload (t)
Distance
Distance shall be calculated using the formula:
Distance [km] = Great Circle Distance [km] + 95 km
The Great Circle Distance is defined as the shortest distance between any two points on the surface of a sphere measured along a path on the surface of the sphere. The Earth can be approximated by a sphere with a radius of 6,366.71 km.
Payload
Payload shall be calculated using the following formula:
Payload (t) = mass of freight and mail (t) + mass of passengers and checked baggage (t)
Mass of freight and mail
Actual or standard mass contained in the mass and balance documentation established in accordance with the Chicago Convention for the relevant flights shall be used for calculating payload.
The actual freight and mail mass shall exclude the tare weight of all pallets and containers that are not payload, and the service weight.
The freight and mail mass over the reporting period shall be determined within a maximum uncertainty of no more than ±2.5%
Mass of passengers and checked baggage
Passengers booked on to a flight, but for whatever reason do not board the plane, shall be excluded from the determination of payload.
Aircraft operators may apply one of two different tiers to determine the mass of passengers. The aircraft operator may select as a minimum the Tier 1 level to determine the mass of passengers and checked baggage. Within the same trading period the chosen tier shall be applied to all flights.
Tier 1:
A default value of 100 kg for each passenger and his checked baggage is used.
Tier 2:
The mass for passengers and checked baggage contained in the mass and balance documentation for each flight is used.
Uncertainty assessment
The aircraft operator shall have an understanding of main sources of uncertainty when calculating tonne-kilometre data. A detailed uncertainty analysis is not required for the methodology of tonne-kilometre data determination.
Reporting
Aircraft operators shall use standardised templates for reporting their tonne-kilometre data. The competent authority may require the aircraft operator to use an electronic template for submission of the tonne-kilometre data report. The Commission may publish a standardised electronic template or file format specification. In this case the competent authority shall accept the use by the aircraft operator of this template or specification, unless the competent authorities’ template [is technically more advanced and] requires the same data input.
Tonne-kilometres shall be reported as rounded values of [t km] (for example 1 245 978 t km). All data per flight shall be used with all significant digits for calculation.
Content of the report on tonne-kilometre data
Each aircraft operator shall include the following information in its report on tonne-kilometre data:
(1) data identifying the aircraft operator and the call sign or other unique designator used for air traffic control purposes, as well as relevant contact details;
(2) name and address of the verifier of the report;
(3) the reporting year;
(4) reference to and version number of the relevant approved monitoring plan;
(5) relevant changes in the operations and deviations from the approved monitoring plan during the reporting period;
(6) the aircraft registration numbers and types of aircraft used in the period covered by the report to perform the aviation activities carried out by the aircraft operator;
(7) chosen method for calculation of mass for passengers and checked baggage,
(8) total number of passenger kilometres and tonne-kilometres for all flights performed during the year to which the report relates;
(9) for each aerodrome pair: ICAO designator of the two aerodromes, distance (= great circle distance + 95km) in km, total number of flights per aerodrome pair in the reporting period, total number of passengers during the reporting period, total number of passenger x kilometres per aerodrome pair, total tonne-kilometres per aerodrome pair (t km).