US carriers continue preparing for the first deadline of the European Union's emissions trading scheme (ETS) even as the airlines lobby for an extension to the 31 August cutoff date.
Airlines with flights within, to and from the EU must submit their emissions monitoring, reporting and verification plans by the end of next month to their assigned administering EU member state in advance of aviation's inclusion in the ETS from 2012.
But airlines contend several challenges exist in filing those plans, including confusion over where to send the information as the EU has yet to finalise its list of administering assignments first issued in February. A final list had been expected in June or July.
The absence of an administering assignment puts carriers in an untenable position since the scheme is being implemented on a state-by-state basis, Air Transport Association of America (ATA) vice-president of environmental affairs Nancy Young says.
Young argues for this and other reasons European regulators are currently unprepared to include aviation in their ETS.
US carriers are also concerned that no EU country has incorporated the aviation directive into its law, and that airline monitoring and reporting requirements remain unclear, Young says.
Another issue raised by US carriers is how to report fuel use, as Young highlights: "Europe's experience with ETS is limited to stationary suppliers. They haven't sufficiently tailored the requirements for the way we actually operate."
For example, carriers must provide both fuel quantity and fuel density but fuel suppliers generally don't measure fuel density.
Site-specific fuel density is extremely difficult, if not impractical, to obtain, she says.
For those reasons carriers want additional time to submit their emissions plans as airlines obtain fuel from multiple sources from airports around the globe.
In addition, there appear to be errors in the preliminary administering list. Those lists show Delta Air Lines and Northwest Airlines as separate entities even though the carries merged in October 2008.
One ATA carrier on the list currently provides no service to the EU. That error has been raised at "high levels" but European officials have not removed the operator from the list, Young says, declining to identify the carrier.
While European officials have indicated all questions will be answered eventually, that is cold comfort for airlines facing a deadline, she says.
"At this point, ATA has only heard general reports that the August 31 deadlines will be delayed," Young says. "Some are saying the delay will be only a few weeks. Others are saying at least a few months."
The association still contends that aviation's inclusion in the ETS violates international law.