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Revision of the EU Emission Trading System Directive concerning aviation

Climate action

This legislative initiative aims at amending the EU Emissions Trading System regarding aviation. Specifically, it will serve to implement the Carbon Offsetting and Reduction Scheme for International Aviation by the EU in a way that is consistent with the EU’s 2030 climate objectives. The initiative will also propose to increase the number of allowances being auctioned under the System as far as aircraft operators are concerned. This proposal will be one part of the broader European Green Deal.

Links

Public consultation

ID: 12494

Lobbying Activity

35 responses

Consultation response

Transport and Environment (European Federation for Transport and Environment), 8 Nov 2021

The Commission is proposing to reform the EU ETS rules for aviation to try and address some unfair privileges the sector was benefiting from and start applying a more effective price on aviation emissions. But it unfortunately continues to implement Corsia, ICAO’s carbon offsetting scheme despite…

Consultation response

Transport and Environment (European Federation for Transport and Environment), 26 Aug 2020

While every other sector’s climate emissions have decreased since 1990, on average, aviation emissions have more than doubled. If the European Green Deal is to radically reduce the EU’s climate impact, it has to reshape European aviation by using all necessary carbon pricing tools at its disposal,…

Consultation response

Climate Action Network Europe, 26 Aug 2020

The aviation sector’s emissions have been growing much faster than other sectors around the world. At the same time the sector continues benefitting from numerous privileges in the EU, ranging from free allocation of allowances under the EU ETS, exemption from fuel taxes, exemption from VAT on…

Consultation response

Bundesverband der Deutschen Industrie e.V., 8 Nov 2021

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location. Besides ensuring the cost-effectiveness of…

Consultation response

Bundesverband der Deutschen Industrie e.V., 26 Aug 2020

German industry is committed to the objectives of the Paris Climate Protection Agreement. The extremely ambitious climate protection goals of the EU for the transport sector also apply to air transport and must be reconciled with economic efficiency, international competitiveness, social concerns,…

Consultation response

Hydrogen Europe, 8 Nov 2021

Hydrogen Europe stands for reforming carbon markets to enable a liquid, sustainable and affordable hydrogen market. A revised, more ambitious EU ETS will be an essential for deep decarbonisation. In this context, carbon content of energy carriers should become the “new currency” of the EU economy,…

Consultation response

DHL Group, 28 Aug 2020

Deutsche Post DHL Group provides an international service portfolio consisting of mail and parcel delivery, express delivery, freight transportation, supply chain management and e-commerce solutions. With approximately 550,000 employees in over 220 countries and territories worldwide, we are one of…

Consultation response

IBERDROLA, 31 Jul 2020

The full internalisation of the environmental costs is required to give consumers a price signal to incentivise the purchase of products with the lower carbon footprint (cheaper) and reduce GHG emissions efficiently. To this end, it is also important that emitters receive correct price signals to…

Airlines for Europe urges EU to avoid double carbon pricing

Airlines for Europe, 28 Aug 2020

A4E urges the EU to align its carbon market with the global CORSIA scheme to prevent double counting. They propose that the EU system only applies to emissions not already obligated by the global program.
This would protect the international competitiveness of European airlines and lower their financial burden.
The environment loses if the weaker global scheme replaces the more rigorous European market.

Lufthansa Group warns EU against double-taxing aviation emissions

Lufthansa Group, 28 Aug 2020

Lufthansa Group urges the EU to prevent double regulation and address competitive distortions. They demand that any reduction in free allowances be delayed until after the COVID-19 recovery.
This strategy would minimize compliance costs while shielding their hubs from foreign competition.
Foreign carriers would lose the financial advantage of avoiding European carbon pricing.

Consultation response

International Air Transport Association, 27 Aug 2020

The International Air Transport Association (IATA) welcomes the opportunity to comment on the inception impact assessment to the revision of the EU Emission Trading System Directive 2003/87/EC concerning aviation. IATA is the global trade association of the world’s airlines representing more than…

Consultation response

Air France-KLM, 28 Aug 2020

With the publication of the European Green Deal in December 2019, the European Commission announced the revision of the EU Emission Trading System Directive 2003/87/EC also concerning aviation, with a proposal to be adopted by June 2021. This position paper constitutes Air France-KLM’s initial…

Consultation response

Aerospace, Security and Defence Industries Association of Europe, 8 Nov 2021

AeroSpace and Defence Industries Association of Europe (ASD) thanks the European Commission for this opportunity to comment on their proposals to amend the EU ETS with regards to aviation and the overall system. ASD is committed to the ultimate objective to reach a net-zero emissions aviation…

Consultation response

Aerospace, Security and Defence Industries Association of Europe, 28 Aug 2020

AeroSpace and Defence Industries Association of Europe (ASD) thanks the European Commission for this opportunity to comment on its plans for the revision of the EU Emission Trading System Directive 2003/87/EC concerning aviation. We consider it essential that a full basket of measures be applied…

Carbon Market Watch demands immediate end to free aviation permits

Carbon Market Watch, 7 Nov 2021

The group calls for an immediate end to free pollution permits by 2024. They want the EU carbon market to cover all international flights. Finally, they argue that charging airlines for pollution helps reduce societal inequality.
This proposal would generate billions in public revenue to help reduce societal inequality.
Airlines would lose massive subsidies and pay much higher costs for their emissions.

Consultation response

Carbon Market Watch, 7 Nov 2021

Please see attachment

Consultation response

European Cockpit Association, 28 Aug 2020

ECA is the representative body of European pilot associations, representing 40.000 pilots from across Europe. More info about ECA at www.eurocockpit.be. ECA supports a gradual reduction of the ETS allowances allocated for free to airlines and strongly urges that the additional revenues generated…

Consultation response

MOL Hungarian Oil and Gas Company, 28 Aug 2020

MOL Group’s answers to the public consultation MOL Group welcomes the European Green Deal and its direction to tackle climate change and make Europe the first climate neutral continent and appreciates the possibility to contribute to the IIA of ETS revision concerning aviation. As general remarks…

Consultation response

Environmental Defense Fund Europe, 28 Aug 2020

3892 pre changes Environmental Defense Fund welcomes the opportunity to comment on the Inception Impact Assessment on a revision of the EU ETS for aviation. When evaluating policy options for CORSIA and EU ETS, the Commission should assess their consistency with the Paris Agreement obligation to…

Airlines for America opposes EU's SAF mandate and ETS expansion

Airlines for America, 8 Nov 2021

A4A requests the EU replace the proposed SAF blending mandate with positive policy measures and incentives focused on accelerating SAF production and reducing costs. They seek exemption of non-EU carriers from international flight requirements and alignment of EU ETS with the CORSIA agreement rather than unilateral expansion.
This would preserve airlines' ability to manage fuel costs and avoid monopolistic SAF pricing during pandemic recovery.

Airlines for America Urges EU to Adopt CORSIA-only Scheme

Airlines for America, 28 Aug 2020

A4A requests the EU implement the 'CORSIA only' option for international flights. They argue applying the EU ETS to international flights violates international law.
This would prevent the loss of funds needed to invest in fuel-efficient technologies.

Consultation response

European Regions Airline Association Ltd., 28 Aug 2020

The European Regions Airline Association (ERA) welcomes the opportunity to provide input to the European Commission’s revision of the EU Emission Trading System Directive concerning aviation. ERA is the trade association representing more than 60 airlines and 150 associate members, including…

Consultation response

International Council on Clean Transportation, 8 Nov 2021

The International Council on Clean Transportation (ICCT) welcomes the opportunity to comment on the Proposal to revise the EU Emissions Trading Scheme (ETS) treatment of aviation emissions. The ICCT is an independent non-profit organization founded to provide first-rate, unbiased technical and…

Consultation response

International Council on Clean Transportation, 27 Aug 2020

The ICCT applauds the European Commission’s intention to secure the aviation sector’s contribution to EU climate goals. While other sectors have made significant progress in deploying renewable energy and improved efficiency to curb or even reduce their emissions, emissions from international…

Consultation response

Deutsches Verkehrsforum, 28 Aug 2020

DVF reaffirms the target of zero emission mobility by 2050. The task of ETS and CORSIA is to give CO2 a price tag, to increase the incentives for low-emission investments and operations, and to offset remaining aviation emissions with effective measures in other sectors. Aviation is a global mode…

Consultation response

Emirates Airline, 27 Aug 2020

Emirates Airline appreciates the opportunity to provide feedback on the Inception Impact Assessment on the revision of the EU ETS Directive 2003/87/EC concerning aviation. As a global airline providing connectivity between European cities and destinations worldwide, Emirates has been a participant…

German Aviation Association urges exemptions for connecting flights

Bundesverband der Deutschen Luftverkehrswirtschaft e. V., 8 Oct 2021

The BDL recommends exempting transfer passengers on connecting flights to EU hubs. They also propose a fixed CORSIA baseline based on 2019 emission levels.
This measure would prevent competitive distortion and maintain the economic equality of EU airlines.

Consultation response

Citizens' Climate Europe, 28 Aug 2020

Citizens’ Climate Europe (CCE) appreciates the EU’s high ambitions to tackle climate change. All sectors will have to contribute to achieve these goals, including aviation. Such efforts must begin immediately and increase steadily. As a global leader on climate change the EU must avoid policies…

German aviation industry warns against double regulation and cost hikes

Bundesverband der Deutschen Luftverkehrswirtschaft e. V., 28 Aug 2020

BDL urges the EU to avoid "double regulation of emissions" and rejects the "swift phase-out" of free allowances. They also request that "revenues from the auctioning of certificates should be earmarked for aviation`s climate protection."
This would preserve financial resources and "maintain the competitiveness of European airlines" during the pandemic recovery.
Environmental groups lose as the industry resists cost increases intended to drive faster emission reductions.

Consultation response

Sonae SGPS, S.A., 8 Nov 2021

Please find our comments in the attached file.

Consultation response

Sandbag Climate Campaign, 28 Aug 2020

Sandbag welcomes the opportunity to give feedback on the Inception Impact Assessment on updating the EU ETS rules for aviation. In the context of the European Green Deal and the enhanced ambition for 2030, changes to the EU ETS for aviation should not result in a step backwards in terms of tackling…

Consultation response

2030 sekretariatet, 28 Aug 2020

In the Inception Impact Assessment it says: The failure to put a price on carbon/climate externalities is equivalent to subsidising polluting activities. This is at the core of the challenge. The Swedish 2030-secretariat was formed to be a collected voice, a coalition of the willing - of business…

Consultation response

Svenska Flygbranschen, 8 Nov 2021

Please find enclosed the comments by Svenska Flygbranschen (Swedish Aviation Industry Group (SAIG)) to the consultation EU ETS - Updated rules for aviation. Best regards, Fredrik Kämpfe Director Industry Affairs Svenska Flygbranschen

Consultation response

Svenska Flygbranschen, 28 Aug 2020

Svenska Flygbranschens kommentarer till Europeiska kommissionen på revideringen av EU ETS, direktiv (EG) nr 2003/87, rörande luftfarten, bifogas.

Consultation response

Coordination Office of the Austrian Bishop’s Conference, 27 Aug 2020

The Coordination Office of the Austrian Episcopal Conference for International Development and Mission (KOO) welcomes the invitation to comment on this inception impact assessment. As we were following the development of CORSIA throughout the last years and pointing out the weak points of the…