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Peer Review

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Notes

Introduction:

Globally, aviation accounts for approximately 4 to 9 percent of the climate change impact of human activity. In the EU it is higher – currently contributing between 5 and twelve percent. Indeed the EU accounts for approximately half of the CO2 emissions from international aviation reported by developed countries.

As the fastest growing source of greenhouse gas emissions the lack of political action on aviation can no longer be justified. It was therefore a welcome move, when in September 2005 the European Commission outlined their intention to bring forward a legislative proposal to include the climate impact of the aviation sector in the EU Emissions Trading Scheme (ETS)3. This is now due by the end of 2006.

Provided the system is designed in the ways in which we suggest in this document we would consider the inclusion of aviation into a Europe wide emissions trading scheme to be an adequate first step in starting to address the climate change impacts of this sector. However, on its own the scheme is unlikely to deliver, at least in the short term, significant emissions reductions from aviation. Indeed, the Commissions communication recognises the need, that, in parallel to the consideration of including aviation into the ETS that existing policies and actions should continue to be strengthened.

e would emphasise, therefore, that inclusion of aviation into the ETS should be developed, not in isolation, but as part of a complimentary package of policies and measures which could include:
• improved air traffic management systems and more direct routing to tackle the formation of contrails and cirrus clouds;
• the immediate ending of VAT exemption, for example with a tax on air tickets. An increase in air passenger duty should also be considered4;
• a kerosene tax on fuel for domestic flights to internalise CO2 emissions, and where there is agreement a tax on fuel on flights between two member states;
• en-route emissions charges (however we note that there is currently a moratorium on applying charges to international aviation for greenhouse gases until October 2007); and
• airport NOX charges.

As it is unlikely that aviation will actually enter into the scheme before 2009/2010 at the earliest (due to the 2 to 3 years it may well take for the legislative proposal to pass through the European Parliament and Council co-decision process) we would like to see these additional measures implemented at the earliest opportunity and certainly before 2010.