Coordination Office of the Austrian Bishop’s Conference
KOO
The Coordination Office (KOO) represents the interests of 35 organisations involved in development cooperation and development education.
ID: 966433512347-76
Lobbying Activity
Response to Revision of the EU Emission Trading System Directive concerning aviation
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 proposed system, we welcome the broad scope of the options presented in this impact assessment.
The current and expected growth of the aviation sector and its emissions are in stark contrast to the needed trajectory towards the mitigation goal of the Paris Agreement and the EUs goal of climate neutrality by 2050. Moreover, the aviation sector currently benefits from some forms of tax exemptions, free emission allowances, state aid to airports and for COVID-19 recovery, etc. which contradict efforts to align the whole transport sector to a 1.5°C compatible net zero emissions economy. Therefore, we want to express our full support for the analysis and feedback to this inception impact analysis provided by Carbon Market Watch (here: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12494-EU-emissions-trading-system-updated-rules-for-aviation/F545795). Furthermore, we want to highlight those options, that will contribute to most to the achievement of the goals of the Paris Agreement.
ICAO’s CORSIA, although it is an internationally agreed model, is not a credible climate strategy and shifting emission coverage away from the EU ETS towards CORSIA would manifest a significant weakening of the carbon price signal on the aviation sector. Therefore, on the link between the EU ETS and CORSIA, option 1 (full coverage of emissions under the EU ETS) is the option with the highest environmental integrity. In fact, this is the option which has been agreed by the co-legislators nearly a decade ago, before the temporary “stop the clock” measure was prolonged for an entire decade. Options 3, 5 and 6 are unacceptable as they would result in a de facto step-back from the current coverage of aviation.
Considering the EU’s role as a climate action leader in the world, we would like to lay out an additional option, where the EU would increase its internal climate action as well as extend the EU ETS to the international scope while at the same time, showing partner countries around the globe EU’s commitment towards CORSIA. We propose that the Commission considers an option, under which the EU ETS would apply to all intra-EU/EFTA flights as is currently the case, and would also apply to emissions from flights departing from or arriving at airports in the EU/EFTA up to an operator’s 2020 levels for those flights. CORSIA would cover operators’ emissions above their 2020 levels, for flights departing from or arriving at airports in the EU/EFTA. CORSIA would not cover flights within the EU/EFTA (the EU ETS would cover such flights).
On the allowance allocation rules, option 1 is the most appropriate option. Given that the current infrastructure of the EU ETS is already very advanced, it is realistic to expect that - from a technical standpoint - it will be possible to shift very quickly to 100% auctioning to the aviation sector. So far, airlines have paid very little for their greenhouse gas emissions in the EU, both relative to the climate impacts created/reinforced by their activities, and relative to their total operating costs. Compliance costs related to the EU ETS have amounted merely to an estimated 0.3% of airlines’ total operating costs according to EASA. All ETS auctioning revenues must be earmarked for supporting climate policies, inside the EU and internationally as international climate finance, the later supporting mitigation, adaptation and loss and damage costs of developing countries.
In order to better address the impacts of non-CO2 emissions, we urge the Commission to make a proposal to regulate non-CO2 effects, as these are both relevant and significant.
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