Impact on sustainable Aviation e.V.
Impact
1.
ID: 100862848402-69
Lobbying Activity
Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies
26 Mar 2025
We appreciate the Commissions efforts at reducing the reporting burden and simplifying reporting requirements. In the context of the Omnibus considering voluntary reporting for out-of-scope companies in aviation such as airlines and aircraft lessors we suggest that a decoupling metric, i.e. decoupling of CO2 growth from traffic growth is being considered. The decoupling approach is already widely used for assessing whether a countrys economic growth is decoupled from CO2 emissions, i.e. it is a proven and tested concept. We have refined such concept for use in aviation. Benefits of the decoupling approach: (1) No need for external, assumption-heavy benchmarks to assess progress; (2) simplicity in calculating and interpreting; (3) allowing like-for-like comparison without discriminating against a business model; (4) reducing the risk of greenwashing. For completeness sake we would like to highlight that neither purely efficiency-based (CO2/RPK (traffic unit)) nor purely effectiveness-based KPIs seem to adequately indicate the status and progress of the transition as a whole. A decoupling metric is essential for such assessment and must therefore complement the aforementioned KPIs. We encourage the Commission to engage with us to discuss the concept in more detail. Transparency and a standardized approach would benefit all parties involved.
Read full response