The European greenhouse gas emissions trading system could collapse in its first year of operation, says the European Business Aviation Association.
The EBAA believes that unless the ETS is simplified for business aircraft operators and small airlines, administrative "chaos" in its 2012 debut year may derail the system. It says, for example, that 38% of operators on the UK list are not registered for ETS reporting, which they are supposed to be by 2011, the year in which the system will be validated.
The problem with the ETS, according to the EBAA, is that it has made its rules with big emitters in mind, then applied the same rules and the same complex monitoring, reporting and verification (MRV) administrative burden to small emitters.
The association has proposed an MRV process simplification that will reduce the administrative burden for small operators and for the system's administrators at European Commission level. This would require a modification to the existing rules before it could be accepted.
The proposal is that small operators, defined as those below a certain emission threshold, should be able to use the Eurocontrol ETS Support Facility emission calculations for each flight to satisfy the total MRV requirement. The ETS Support Facility, formerly known as Pagoda during its development, has already been EU-approved as an ETS verification tool. The EBAA argues that, providing its accuracy levels are validated, small operators should be able to use that as their reporting tool, and to calculate their trading dues on the basis of Support Facility-derived emissions levels.
The EBAA plea is that the current threshold for small operators of 10,000t of CO2 annually needs to be much higher to take into account the emissions that are in reality produced each year. This will enable small operators to be able to use the ETS Support facility as their MRV.
EBAA president Brian Humphries says this would mean the operators pay for their emissions just as big carriers do, but without facing the disproportionate amount of expensive bureaucracy at airline and European Commission level that would be generated by the MRV system designed for the big carriers.
The EBAA argues that, since aviation as a whole contributes 2% of greenhouse gas emissions, and business aviation only 0.04%, applying overbearing bureaucracy to that minute sector is unjustified when a simple alternative is available.
Source: Flight International
