So, having spent all weekend reading a shedload of euro-legalese-bull, I now have a better idea of what is involved and what they think it will all cost.
The bad news is that the laws have already been passed and they didn't feel it necessary to tell the people concerned what the impact would be. There was a consultation last year on the monitoring and verification process that didn't attract a reply from a single GA operator (unless you count Netjets) - did anyone know about it?
Everyone who operates an aircraft over 12,500lbs (5,700kg) will be required to "join the scheme". There will be an exemption for small airlines, operating scheduled services, up to 10,000 tonnes CO2 per year or 243 flights per 4 month period. The fines for non-compliance, ignorance etc are capped at €50,000.....so that's OK then. The disparity between the treatment proposed for aircraft operators and the way that fixed installations were handled (in the first implementation) is staggering - the politics of envy is alive and well.
The scheme is illegal under the Open Skies agreement for airlines and has been condemned by every industry representative body that I've read so far. Get writing folks! We need to drown them in paperwork.
I have a couple of pages of comments on the scheme that I will be sending, attached to the consultation, because there is no scope in the questionnaire for telling them what you think about the scheme; only discussing the nuts and bolts of implementation.
Personally we will be withdrawing from that business sector - 3 qualifying flights in one of the previous 3 years makes it impossible, financially, to comply. I don't yet know what will be required to get our name taken off the "hit list". Incidentally, the first draft hit list was compiled by Eurocontrol using ICAO callsigns....just because you don't have a callsign doesn't mean you won't be going on the list.