European Union Emissions Trading Scheme (ETS)

[Mike Echo]

Consultation on Transposition of EU Directive (EC/2008/101) to include Aviation in the European Union Emissions Trading Scheme (ETS)

Rarely do I feel moved to start a thread but I suspect many Operators will not be aware of the impact of this legislation which may require monitoring next year followed by implementation in 2012.

Although the topic has been raised before on PPRuNe, our company (and maybe yours) has now had a letter from the Department of Energy and Climate change, Go to the following

Consultation on including aviation in the EU ETS - Department of Energy and Climate Change (http://www.decc.gov.uk/en/content/cms/consultations/aviation_euets/aviation_euets.aspx)

and then a pdf “Letter to Consultees”

The DECC contact number is a voice mail - I assume they don’t really want to talk to you directly.
So far the e-mail address hasn’t worked -oh hum

After that you are on your own to dig into a minefield of legislation.

I don't know how this information is being distributed to Operators outside the EU?

It is something that will have a cost element to nearly all Corporate/AOC operators no matter what their registration.. There are some exclusions but not many.

So far as I can see
1) In spite of what they say it is a tax. There are some estimates what it will add to the price of airline tickets. I not found any estimates for it's impact on Corporate/AOC
2)For corporate, if you are, for example, flying direct from the US to the EU you will will be assessed on the entire leg - not just the time within Eurocontrol and of course on the return.
3) You can apply for a free allowance but this looks to be only about 5% of your total and would involve a lot of paperwork plus a Verifier to come in and check your paperwork. A simpler system may be possible by giving up the free allowance.
4)A very rough calculation for our small company jet indicates a cost of between 900 Euros and 18,000 Euros (Carbon @30Euros/Ton) a year for 400hrs depending on the value Carbon is trading at if all of this flying was within the EU.

Being old and cynical I would not expect anything from this “Consultation” but you never know. This consultation ends on the 14 May 2009 -no pressure.

There is an awful lot of information not exactly hidden but buried within various links.

I'm still working through this but the simplest thing is to just fly and pay which is what it will probably come down to!

Over to the PPRuNe experts to put my mind at rest:confused: Well 2012 at least takes me nearer to retirement!

Mike Echo

[Flying Binghi]

Rarely do I feel moved to start a thread but I suspect many Operators will not be aware of the impact of this legislation

A very small number of ppruners have been covering ETS and related subjects.

Wake up muppets...:hmm:

[Daifly]

The letter arrived on my desk yesterday and whilst I'm aware that BBGA are responding to it, I think it's very important that individual companies do as well - another tax at the moment is not what we need to keep this industry alive. I am not shirking my environmental responsibilities, but a delay in implementation is required given the turmoil the rest of the world is causing.

I really would appreciate knowing other people's arguments for this, just in case the one I am forming isn't deep enough to hit home in Whitehall...

But we MUST all respond.

Daifly

[HS125]

Environmental responsibilities don´t come in to it, This is a TAX and will simply drive up costs, nothing more. We must however all respond.

With regard to the levy being calculated on the whole leg, not jsut the eurocontrol portion, My understanding is the US/Canadian authorities are really upset about the prospect of the EU generating tax revenues from flights conducted in their airspace.

[rotorknight]

I guess that the americans\canadians will just add their own tax on top of our lovely european bit:ugh::ugh::ugh:

[Sepp]

Aren't we lucky to have to pay 750 quid each, to have them look at our emissions plan - in addition to the payments we'll have to make.

And it's so understanding of them to impose such lovely fines if we don't toe the line by end of August - 5 grand, plus 500 a day. Don't pay up within 6 months? Prepare to have 'em sell one of your aeroplanes...

Nice.

[Mike Echo]

Just in case you wanted to check out if your aircraft is listed and who your "Competent Authority" is go to

http://ec.europa.eu/environment/climat/pdf/aviation/alloc_operators_110209.pdf

The annex contains a list of aircraft operators to be administered by each Member State. Curious that the US is listed as a Member State for administration wonder if they know yet:rolleyes:? Although this gives you the Country, who the Competent authority is is not listed. In the UK it could be the "Enviroment Agency", CAA, or DOT. This seems to be very vague.

As Daifly said BBGA is well up on this

Mike Echo

[HS125]

The other issue here is we´re panicing about how were going to comply with all this.

The real answer is for EVERY operator on that list to write to their competent authority and tell them exactly where to get off. I´d like to see them put a stop to Aviation in Europe because they pushed us too far and wouldn´t take another airhead pocket-lining scheme.

It´ll never happen I know but It IS the answer.

[Paradise Lost]

No need to be cynical about this new TAX, because HMG has already told the EU parliament that it does not intend spending it's share of this windfall on environmental projects!
This is just the beginning of the massive clawback that is required to service UK's national debt. While BBGA and all other operators should take umbrage and represent their objections, unfortunately it is all too late, as this plan is now a "fait accompli" in European law.
The only real hope of getting it deferred, or better still rescinded is for the rest of the non EU world to object through the WTO.

[flyingfemme]

Well that looks like we are out of business...........

For an "operation" that buys around 50usg of fuel a WEEK the overhead is going to be ridiculous.

Why are these people so set on killing that goose that pays the golden taxes?:ugh:

[Empty Cruise]

Paradise Lost,

Sorry to rain on your parade, but the UK "only" runs a debt of arround 45% of GPD. Schermoney runs close to the 70%-mark, but they will still weigh into the ETS at exactly the same level as the UK.

Therefore, the "clawback" argument seems feeble. They claim it because they want us to produce less emissions. As people have said, companies will go out of business, thereby producing less CO2, NO2 etc. etc., fewer seats available and only larger operators will survive = higher seat price, fewer flights = mission accomplished.

It's not because they want your money (ok, they'll take it as a windfall, thank you very much), they want fewer flown seat kilometres. Being under any illusions in this respect is not going to help us.

Look at it this way - it's a CI regulator. Most corporate outfits have such small fleets and so few seats that maintenance is the biggest cost. Therefore, we fly around at speed rediculous or CI=200. With the ETS, ECON speed will be brought well below Mmo. It's no different than taxing your petrol - if each litre of petrol cost 100GBP, you wouldn't drive your car as much or in the same way as you do now, would you?

The unfair bit is that many other businesses with huge emissions were given carbon credits for free as grandfarthering rights, emissions they can now trade at a profit. I haven't heard anybody mention what emission allowances will be grandfarthered to the aviation industry (but then again, I've been too lazy to look it up myself :rolleyes: ).

As a way of regulating human behaviour, nothing has ever come close to taxes... or risk of punishment - maybe that should be considered? If you exceed your emissions allowance (or fail to reduce it along a schedule), first the CEO goes to jail. If that doesn't work, we'll have the CFO as well. The rest of the board can follow in whatever order the company can best spare them! :}

[Empty Cruise]

OK, that didn't take long to read up on - so here's te deal:

1) Take the no. of pax and multiply by 100 kg. (or the mass of your freight)

2) Divide the result into a 1000 kg. This is your "tonnage"-figure

3) Take the distance you've flown based on your flight planning softwares route calculation and multiply by 1,852. This is your "kilometers"-figure

4) Multiply "tonnage" by "kilometers" to obtain TonnesKilometers (or TKm)

5) Submit a paper stating the above to DfT no later than 31/08/09.

6) Include a cheque for 830 GBP for them to approve your plan.

7) Include a new field on every flight envelope marked "TKm" and let the crews do the calculation after every flight.

8) When the envelope comes in, enter the TKm value for each flight in the benchmarking year 2010.

9) Jan 1st 2011, call in your accountant (or anybody else that could work as a "verifier") - make them countersign you TKm total for 2010.

10) Send in your verified accounts for 2010 and obtain your free carbon allowance.

11) The smart operator will - anticipating changes to legislation at a later date to account for fuel savings etc. - already now calculate how much fuel they burn pr TKm. Make the crews take actual fuel burn (from tech log) and divide it by the TKm, giving you tonnes of fuel pr TKm or T/TKm.

12) Scream to your legislator that your company uses CDA-approaches and have bought a brand new GLX5K in stead of the old, smokey G4. Demand that actual emissions be taken into account. When that happens, you'll be glad you've already got all the data from item 11) above.

13) Fly a lot in 2010 - even if it's at a loss!!! Those carbon credits are gonna be nice to have in the carbon bank for a rainy day! You could, e.g. sell them on (cue evil laughter!)

14) When you recieve your allowance, make an optimistic guess that you'll fly 10% more TKms than your allowance. Then spread the cost of this over every charter you do.

15) Wait & see what happens. Either all your clients run screaming for cover and drop all flying activities - or they bite the bullet and still fly, maybe not quite as often as before, but they still fly. If you can survive on that - good. If not... :ouch:

[flyingfemme]

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.

[Sepp]

'Tis true that the Directive includes exemptions, but it seems that the UK has "forgotten" to include them in the 2009 Trading Scheme Regulations - or if they have, I couldn't find them. I'd be really happy if someone could do so...

http://www.decc.gov.uk/Media/viewfile.ashx?FilePath=172_20090305171439_e_@@_AviationRegul ations.pdf&filetype=4

[flyingfemme]

The exemptions aren't mentioned in the UK documentation because the law has already been enacted, centrally, and they have no powers over that legislation. The individual members states are in charge of monitoring, verification and punishment - that is what the UK document is concerned with.

The doc you need is this one :
EUR-Lex - 32008L0101 - EN (http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32008L0101:EN:NOT)

and the exemptions are right at the end :
This activity shall not include:
(a)flights performed exclusively for the transport, on official mission, of a reigning Monarch and his immediate family, Heads of State, Heads of Government and Government Ministers, of a country other than a Member State, where this is substantiated by an appropriate status indicator in the flight plan;
(b)military flights performed by military aircraft and customs and police flights;(c)flights related to search and rescue, firefighting flights, humanitarian flights and emergency medical service flights authorised by the appropriate competent authority;
(d)any flights performed exclusively under visual flight rules as defined in Annex 2 to the Chicago Convention;
(e)flights terminating at the aerodrome from which the aircraft has taken off and during which no intermediate landing has been made;
(f)training flights performed exclusively for the purpose of obtaining a licence, or a rating in the case of cockpit flight crew where this is substantiated by an appropriate remark in the flight plan provided that the flight does not serve for the transport of passengers and/or cargo or for the positioning or ferrying of the aircraft;
(g)flights performed exclusively for the purpose of scientific research or for the purpose of checking, testing or certifying aircraft or equipment whether airborne or ground-based;
(h)flights performed by aircraft with a certified maximum take-off mass of less than 5700 kg;
(i)flights performed in the framework of public service obligations imposed in accordance with Regulation (EEC) No 2408/92 on routes within outermost regions, as specified in Article 299(2) of the Treaty, or on routes where the capacity offered does not exceed 30000 seats per year; and
(j)flights which, but for this point, would fall within this activity, performed by a commercial air transport operator operating either:fewer than 243 flights per period for three consecutive four-month periods; orflights with total annual emissions lower than 10000 tonnes per year

In other words; anything that does not currently attract Eurocontrol will be exempt as will "small airlines".

[Sepp]

Thank you for your input, FF :ok:

One suspects that the Regulator will still require the small fry to submit plans (together with the non-refundable fee, of course), if only to prove that they don't have to. It all adds up, and Mr. D is a bit short of readies atm.

Cynical, me? Never!

[inner]

This is Europe my friends. A totalising power who doesn't indulge any country identity and imposes their will. And as a country if you don't agree, you'll get punished. Europe is not that democratic as many people think.

This is just a new money making machine. If the money is being used for environmental purposes, than i would say ok, but it will not. That's for 100% sure.

I'm wondering what the effect will be on aviation employment.

[flyingfemme]

If it is a new money making machine then it's been very badly designed!

The fees charged to the operators will only cover the costs of setting up the scheme - 25 times because each state will do its own.

Free credits will be given out to airlines up to 97% of their benchmark 2006 emissions. Great for airlines with old-tech gas-guzzlers.

A small percentage (15% I think) of credits will be auctioned so some money will be gathered.

After that we will all have to trade on the global exchanges - so the dosh will be made by other industries that already have mucho credits and can swap to renewables or move their huge industrial facilities outside the EU. Aviation can only used approved fuels so the possible savings will be meagre unless business goes totally down the gurgler. In that case the value of a few, measly credits will probably not be significant.

The point is that the costs of compliance are likely to be greater than the costs of the actual carbon credits for some small operators! It is so badly designed as to be criminal.

[Sepp]

Did anyone else here go to the ETS seminar at Manch yesterday? I'd be interested to know what you thought of the presentations, and the children who were representing the Govt. ... for those who weren't there, one appeared to be about 9 and the other's vocabulary seemed to consist of just "Um" and "Er".

Some good points were raised by the audience - and it was painful to watch the panel squirming at their inability to satisfactorily answer many of them.

[Mike Echo]

Didn't get there myself but will be attending the Heathrow one tomorrow. I got some feedback from a friend who did attend and his summary agreed with yours that it was a somewhat heated discussion. Lot of "Um's" and "R's" but with little help other than quoting the regulations.

I've raised several questions on the Environment Agency "helpline" but apart from a couple of answers they tend to quote various regulations which don't answer the question. I suspect maybe wrongly that they don't have any real understanding of Aviation and Business Aviation in particular.

I have noticed that the EA now have some further documents on their website which need to be read.

Environment Agency - EU Emissions Trading Scheme - Aviation (http://www.environment-agency.gov.uk/business/topics/pollution/107596.aspx)

Guidance for the Aviation Industry
http://www.environment-agency.gov.uk/static/documents/Business/EU_ETS_Aviation_guidance_1.0_280509.pdf


ANNUAL EMISSIONS MONITORING PLAN
http://www.environment-agency.gov.uk/static/documents/Business/Annual_emissions_(Corporate_aviation_operator).pdf

TONNE-KILOMETRE MONITORING PLAN
http://www.environment-agency.gov.uk/static/documents/Business/TKM_exemplar_(corporate_aviation_oerator).pdf

I'll see what tomorrow brings - but I'm not expecting much

If you are inclined go to the following;
http://ec.europa.eu/environment/climat/pdf/aviation/consultation_mrv2008/10.ata.pdf
and go to Page 17 Section 4 which it the ATA response to the consultation document it starts with "The Effort to Encompass International Aviation within the EU ETS is Illegal" Interesting reading!

Mike Echo

[Sepp]

I suspect that your suspicions are not too wide of the mark...

Come the Q&A session at the end of play, you might like to raise the issue of who exactly can use the 'small emitter' simplified reporting route - it was said at Manch that its only available to qualifying CAT operators, but the guidance material and exemplars say its only non-CAT that can use them, and that small CAT operators which satisfy exemption 11 are excluded from the scheme completely!

Bit of a dog's dinner, really....

[flyingfemme]

(j)flights which, but for this point, would fall within this activity, performed by a commercial air transport operator operating either:fewer than 243 flights per period for three consecutive four-month periods; orflights with total annual emissions lower than 10000 tonnes per year

And I understand "CAT" to be AOC operators........

[Sepp]

Yep, that's correct, CAT=commercial, and from the guidance material (sect 2.3, 2nd para):

"The simplified approach is open only to non-commercial operators below the above thresholds. Commercial air transport operators are altogether excluded from the scope of the EU ETS scheme if they remain below the thresholds."

We have now heard from the EA that we're no longer on the list, so can forget about the whole thing entirely. Plus Hazel Blears and Ms Smith have gone, so it's been quite a good day, really. :)

[4HolerPoler]

Just spent a few days (collectively) dredging through the Environment Agency (creating a better place) :} website doing our submission. Still a month from the deadline and the tosspots have been on the blower reminding me that I'm approaching the deadline. No guarantee that they'll approve your plan (no pass/ fail criteria listed), restrictions in many submission fields of no more than 250 characters (including spaces); a load of drivel, dreamt up by someone who clearly has very little insight into the vagaries of aviation but is way up there on the bureaupole. Sweeping this aside, having lovingly constructed a data flow chart of how I'm going to collate this crud, I am thrilled when I realize that I'm finished with the forms. Eagerly punching the puce green Submit button, I'm assailed by the next page demanding £ 750 for my misery. And, no, you cannot pay with your Amex card. Somehow they've forgotten to stick VAT on.

What an enormous crock of swill.

The owner has already voiced his opinion of the whole scheme as a giant rip-off - now I've got to tell him to chip in 750 quid for the pleasure.

Rant over. But it's a sad day for aviation.

[readymessage7700]

Afternoon all,

Not that this industry needs another good kicking, but the date is almost upon us where this tripe has to be complete. Despite numerous dates kicking around on the official website I am aware the "new" date for completion is 12 Nov.

Wondering if everyone has completed theirs yet? :ugh:

[Chinchilla.612]

readymessage7700,

We got allocated to the Greek authorities and had it in for the end of August, as that's when they asked for it by.

Still being put back all the time now though is it?!

What a shock. lol

[lear60fellow]

I´ve been reading the whole thing but can´t find any subject related to private flights or private aircrafts not flying commercial, have any of you found anything? I´m really interested on that point

[lear60fellow]

Well, searching on internet I found this

http://www.environment-agency.gov.uk/static/documents/Business/FAQ.pdf

Subject 3

[stickjoc]

HELP!
Has anybody got a sample flow chart that can be edited for my submission?
thanks
stickjoc

[Mike Echo]

Sent ours in last week and have already got back some questions about our submission. They still have no concept or understanding of a small Private operation. As we operate only one small aircraft with two crew the section about what risks are there that could lead to omission of aircraft that have been operated I entered "No Risk. " Not a good answer it seems. Our "Data Flow Diagram" was "too basic" - which was my intention, Ah well now to complicate it!
For those who haven't got to the end, when I did ours there was no facility to pay on-line you have to telephone and pass the details. I also go the distinct impression that they had only got a small fraction of the 900 aplications that they were expecting!
Oh what Fun
M.E.

[4HolerPoler]

My experience exactly. They insisted that I refer to structures within our company that don't even exist just to satisfy their own jargon-machine. Make sure you're having a good day before you start your TKM application - it will have grown men crying with it's obstinate bureaucracy.

Have received confirmation this week that our handling company is prepared to manage the scheme on our behalf but it'll cost $ 3,000 for the set-up, $1,250 per year and $ 5 per leg. Money well spent in not having to interface with these bean-counters.

stickjoc - I downloaded some data-flow software - it was Java based that allowed me to build my data-flow diagram & then convert it to PDF for submission - it was on a trial basis & was no charge but took ages to build. PM me if you can't find it on Google & I'll dredge up a name.

[His dudeness]

+ 1 for Germany.

I fly for a company that already has to trade emission rights for their plants and therefore have a 5 guy strong subsection to deal with that crap. Have submitted our concept as one of the first, had just 2 days ago an answer.

Apparently our way of dealing with fuel denisty is a nono, they want it for every refuelling (our fuel indicating system compensates for density changes until the lowest probe surfaces [not longer fully submerged] - which is at 800lbs a tank, never landed with that low amount of fuel jet)

Checked the fuel slips - 2 thirds of them don´t even carry the density on them.

According to our emission guys we emit less than the tolerance of their plants in the EU is.

Why we have to do that **** and the small commercial guys with the same airplane are exempted is beyond me. Me thinks EBAA or whoever goofed there.

[stickjoc]

4 Holer, thanks i managed to do it with hrs to spare to the deadline!, it is such a load of c%$p, i find it beyond belief how these people think in such a narrow minded way, or on the other hand how lucky we all are to be able to leave it all behind and go flying!

[flyingfemme]

I had some gossip (as yet unverified) that one small operator has been given an exemption by virtue of the total expected emissions..............anyone care to comment on that? As far as I can see there are no exemptions (apart from the small scheduled airline thing).

[Sepp]

We are a small ad hoc charter outfit, and have been exempted*:

based on the evidence that you provided (a copy of your Air Operator Certificate ... (aoc number removed) ... and current 2009 flight data) and our review on the emissions and activity data provided by Eurocontrol for the period 2006-2008, ... (company name removed) fore fill (sic) the requirements for exemption from the EU Emissions Trading Scheme under subparagraph (j), Annex 1 of the Directive. Therefore you are not required to submit an emissions monitoring plan at this stage.

*is that even English?? lol.

[flyingfemme]

Interesting.....how does that fit with the rules as published? The small emitter rule said something about 243 flights per quarter or 10,000MT CO2 but specified city pairs and implied that it had to be scheduled flights. Is that not the case?

[Sepp]

Nope. You do have to calculate your emissions between city pairs - using the GC dist between the two plus 95 km (from memory) - not just say "we flew 12,000 km in the last year", etc. If you have an AOC, and you are under the threshold, it would appear that you are out of it - no rqmt to be a sched operator. We come under the UK umbrella, I should add.

It has to be said, though, that this year has been a very quiet one for us - it won't take much of an upturn for us to have to submit. :{

[Kak Klaxon]

Really confused now, how can they check euro control emmissions data for SEPP over the last 2 years when PAGODA does not work yet?.
Maybe it depends on who you talk to at the Environment Agency. Still waiting for feedback on my pathetic submission.

[Sepp]

You know? I have no idea... however, I have it in writing so I care further as much as the system cares for us.

Best of luck, all - and frankly to me, too, when I finally have to roll over.

[Mike Echo]

Just picked up the following from AIN News;
"The UK Environment Agency is giving operators more time to register their plans for monitoring, reporting and verification of carbon dioxide emissions under the European Union’s emissions trading scheme. The deadline for registration fell on November 12 and a large but unspecified number of operators still hadn’t completed the process by then. A government spokesman indicated to AIN that the agency will not be levying fines at this stage."
Why doesn't this suprise me.

Not heard from them since my third corrected submission, once through the initial stage it apparently goes to a "peer" review - no idea what that means.
Now back to some real work making a cuppa while it's still allowed.
M.E.

[4HolerPoler]

Allow me to confuse the issue even more by quoting my point-of-contact within the Environment Agency:

The use of PAGODA is not allowed, if you just refer to the fact that you are going to be using a commission approved tool then this will suffice.

This in response to my initial application :bored::confused::bored:

I'm as confused as Punch - you may not nominate PAGODA (because it's "not allowed") but you can nominate a "commission approved tool" (of which there currently are none) and that'll be fine.

:ooh:

[Mike Echo]

Ditto
Been there and had the same answer. Also confused :confused:but this is becoming a permanent state. Still not sure how to write procedures using "tools" that don't exist.
M.E.

[Kak Klaxon]

Just got the feedback from the ETS on my submission. I would of been better writing "cock" in each of the required answers rather than trying to tie in what they want with our operation. I now have to make up more non existing departments and post holders in our two man operation to get the form approved.
Has anyone got through this yet?

[Mike Echo]

Not sure what's supposed to happen next, they went all quiet after my third submission. Possibly still laughing. I presume everybody is the same but my EU-ETS file is now just about equal in thickness to the Flight Manual.
M.E

[Kak Klaxon]

FMOB I got approved, now to see if my made up b/s system will work when they want my first report!

[4HolerPoler]

This is non-aviation related but directly related to these blood-suckers:

EU's 'carbon fat cats' get rich off trading scheme

Europe's system for industrial carbon quotas has enriched the continent's biggest polluters, with ten firms together reaping permits for 2008 alone worth 500 million euros, a new report revealed. Dominated by steel and cement makers, the same "carbon fat cats" stand to collect surplus CO2 permits that -- at current market rates -- could be worth 3.2 billion euros (4.3 billion dollars) by 2012, it said. This is roughly equivalent to the entire EU investment in renewable energy and clean technology under its economic recovery plan, according to Sandbag, a non-profit group in Britain that analyses carbon market policy. "Emissions trading is meant to be the central policy for cutting CO2 levels," said Anna Pearson, Sandbag's top policy analyst. "The fact that companies are able to make large sums of money for doing nothing highlights that the trading scheme must be reformed and EU climate change target strengthened."

Under the Emissions Trading Scheme (ETS), the European Union allocates carbon polluting allowances to member states to meet obligations laid out in the UN's Kyoto Protocol, for which the first commitment period runs through 2012. The states then assign quotas to the industries that belch the most CO2 into the atmosphere. Companies that emit less than their allowance can sell the difference on the market to companies that exceed their limits, thus providing -- in theory -- a financial carrot to everyone to become greener. But the energy, steel and cement sectors that dominate the system, hit by the global crunch, are emitting less CO2 than forecast, which means surplus carbon permits are flooding the market. Among the top ten beneficiaries, steelmaker ArcelorMittal collected more than 40 percent of the 2008 excess permits, reported Sandbag. French cement giant Lafarge got about 12 percent, with Tata steel group subsidiary Corus and Swedish steel maker SSAB-Svenskt Stal each claiming about 10 percent. Even if the permits are not directly resold for profit, the value will still remain on the companies' books, rising or falling with the market. Most of the permits were generated simply because the companies were allocated more free permits than they wound up using, according to the report. "Little or no actual 'effort' toward emissions reductions need have taken place, yet these companies will be able to literally bank the profits," it said. The price of a tonne of carbon dioxide (CO2) or its equivalent has fallen sharply over the last 18 months. After peaking at nearly 30 euros (38 dollars) in mid-2008, CO2 is currently trading at about 13 euros, according to BlueNext, one of several European carbon exchanges. Viewed narrowly, the recession-driven drop in CO2 emissions helps the environment. But low carbon prices give businesses little incentive to develop and install new technologies to slash future emissions.

Think the same is going to happen in aviation? You bet your sweet @rse it is!

[Mike Echo]

Just for those who might not have seen it I was at a meeting on the 19th February where the DFT were discussing penalties and charges. In spite of the Government making money out of this scheme during the Auctions they are also going to charge a "Subsistance" amount to cover administration costs. But don't worry!!! most biz jets aircraft will fall into the 1st charging band so they will "only" charge you £2,550 each year. Our single company aircraft will produce around 300 tonnes of CO2 a year incuring a Tax (they don't like the word Tax so I tend to use it) of around £8,000 depending on Carbon values. So including the annual verification charge say £1,000 (I don't know what this will be) we could end up paying £3,550 for the honour of paying £8.000 TAX. This seems slightly ridiculous to me but not to the Emissions people

Whilst at the meeting the BBGA produced some interesting numbers that from a total UK list of 894 Operators 269 Operators have their plans approved with another 100 in work. 174 have been exempted with 10 in work This leaves 341 (38%) unaccounted for.

Also the Pagoda repacement system for small Operators seems to have a problem and is still delayed.

Rant over for the moment

M.E.

[keithskye]

and have a meeting to see where each of us stands in the whole process (I have my AEM plan approved and working), and see if we can improve or refine what each of us has or is doing to comply with the requirements (forms, procedures, etc.). Possibly there may be a benefit to pooling resources in some way. I do have some ideas...

Keith McLellan
CL-604, M-JSTA
EGGW

[flyingfemme]

Think the same is going to happen in aviation? You bet your sweet @rse it is!

Only if the airlines fly less......other industries have choices that just aren't available in aviation. Large industrial polluters can move factories out of Europe (but still have their credits) or use alternative energy sources. Airlines can't move or use another fuel. They are also targeting tiny emitters in aviation but only huge emitters in industry - it's the politics of envy in action.

[cambioso]

Has anyone actually been served with a "civil penalty" yet for refusing/failing to file their application for an emissions plan?

[Mike Echo]

Not that I've heard of, but they are still trying (and not succeeding yet) to compile complete, and accurate lists.
At the risk of sounding sarcastic :O the main culprits for being late seem to be the various Government departments, EU Commission, and the Environment Agency. As for a "Pagoda" replacement who knows. I just can't think of a way we could fine them :confused: as it's not built into the legislation for some reason.
I'm just collecting data and writing procedures where I can.

Mike Echo

[cambioso]

"As for a "Pagoda" replacement who knows. I just can't think of a way we could fine them as it's not built into the legislation for some reason."

Sorry Mike, what do you mean here?

I'm trying to find out whether anyone has actually been served with a "civil penalty" (whatever one of those is ?!) for failing to pay their £750 to have their plan "accepted".

[mattman]

This is the most useless thing ever to come out of Europe and we are going to pay for it.
The EBAA has said it will tell there members to stop complying if they do not introduce the small emitters tool.
We have all put our Pargoda or other tool in our application for the monitoring but nobody knows when this will be implemented.

And the multitude of leaches that have climbed onto the band wagon. This has created a whole new sector in the aviation industry and they are capitalising on this for every cent. The first couple of years will cost you not only your emissions but to support this sector, and will probably double your emissions costs.
One is so cheap that they will not phone you unless you have skype, but you have to phone them.
And to let the fun really begin, wait until we have to start to buy and trade the emissions :yuk:

I heard there are some international airlines that are taking them to the Eu court to drop this with them.

It threatens our flight departments and our jobs, and to really cap it off the muppets that are running it are not aviation agencies but environmental agencies, so no clue......:ugh:

My rant is over now going to the boss to explain the next costs to flying his aircraft......

P.S.
Sorry to answer your question, nobody has been fined that I know of, and if they did they would have a really tough time as was said there has not been a final list, these idiots have not included just European aviation but the entire world, how would they fine you when "Sahid" in Sri Lanka has not even bothered to even open the letter. They will have to prosecute everybody then

[Mike Echo]

Hi Cambioso
"As for a "Pagoda" replacement who knows. I just can't think of a way we could fine them as it's not built into the legislation for some reason."

I didn't phrase that very well. I was just wishing we could fine the Government for their delays as they seem very keen to threaten Operators with penalties.

M.E.

[cambioso]

Thanks M.E. good point!
It seems that these people are threatening people (like me!) with these "civil penalties" if we don't pay the £750 tax to have our (painfully completed) plan accepted.
Has anyone been served with such a penalty yet?
We had our plan accepted online back in November (we have the email saying so), but we forgot to pay the £750 tax.............. ;-)
I said I would pay the money IF the system went live in 2011, and IF we still had our aircraft. I said I would pay the tax, but I asked them to confirm that if we sold our aircraft, or put it on an AOC before 2011 they would refund me our £750............they didn't like that and kept saying over and over again "Resistance is futile"!!
It comes down to whether these penalties actually exist or are they just some nasty threat?
Anyway guys, let's hang on in there.........I'll bet this poxy department will disapear soon with the new government cuts?!

[NuName]

It would be interesting to know just what exactly is to be done with all this money. Are they going to plant trees? If any commercial organisation attempted to extract money from legitimate entities with menacing behaviour, as they are doing, it would be addressed as extortion. Another example of an unelected body imposing regulation on an industry already on its knee's, god know's how many job's this has cost, now and in the future.

[Mike Echo]

As far as I can work out the Government have no intention of using any of the raised cash for "planting trees" It will just go into the Treasury coffers, after all no matter how fancy the wording "Emission Trading Scheme" it is still just a tax:D
M.E.

[Kak Klaxon]

Did you all know that the environment agency have given all our details to third parties under a freedom of information request?, got my first mail yesterday trying to sell me an E.T.S package, so much for security.

Commission approved tool = Neil Kinnock

[nafod]

Sepp,

This may or may not be of help but..... If your flight department/office/ownership etc has a viable AOC....and flies into EU airspace less than the minimum specified in the verbage......and you operate under the name of the AOC.....you are exempt.

You must provide them with the AOC copied, perhaps the declaration of your Insurance certification showing "commercial" liability minimums.

Their response to my response......admitting stupidity and letting the deadline come/go was....."show us your commercial operation details".

Since they cannot tax the cows farting in the pastures.....they will get it somehow. Usually from those who HAVE NOT BEEN TOLD how to qualify for an exemption. This info may help a few. We are exempt now as a commercial operator....this applies to non-scheduled pax/cargo.

Regards, NAFOD

[Sepp]

nafod Cheers, mate - our outfit is indeed an AOC operator. I'm aware of the "cut-off" point and the attendant niceties, but hopefully your contribution to the discussion will help others :ok:

Fortunately (hooray!) we currently operate under the prescribed limit.
Sadly (boo!!) we are EU-based and expanding so we won't escape for much longer, however, I'm (completely and selfishly) delighted that it will only be my problem for the next eight days; then some other poor sod gets to deal with it. :E

All I need is another job, now... :p

[active70]

@Sepp

The same (EU-based AOC operator, below minimas but expanding ...) applies for us. According to the information we've received from Unité ETS at Paris, for the time being "no furhter actions are required. If you don't fall anymore under the "de minimi" threshold, then Eurocontrol will know it and add you into an updated list of aircraft operators". This all sound very confusing if not chaotic to me ... and I refuse to believe that expanding small operators are well advised to do nothing, therefore we have decided to do a statistical analysis of fuel used from 1.1.2010 on our side (although Paris' response to it was "you can do it in order to be sure of your situation but it is not required"). Other than that we just wait and see ...

What are you doing? Do you have other statements?

Regards, A70

[Sepp]

A70 Well, like I said earlier, I'm on the brink of leaving the company - it's not exactly great being without a bread-and-butter job in these uncertain times, but I'm already enjoying not having to do anything at all about ETS and various other EASA/EU faff, so it's not all bad news!

I agree that the lucky few are ill-advised to sit on their hands; rather they should be using the time to get ahead of the game - however, I was instructed by the AM/CEO to not expend resources pursuing the matter, further than monitoring our position relative to the threshold and reporting at the various management meetings. That, I have done. I have no idea what my successor is going to do when the time comes, as I am no longer party to that sort of discussion. I'm sorry I can't provide a more helpful answer.

[mattman]

Well here it is, for us small emitters the tool has been published, dont know wether to cry for joy or just cry.... good Luck

Small emitters tool
It is recognised in Part 4 of Annex XIV of the Guidelines on monitoring, reporting and verification (Decision 2007/589/EC) that small emitters should be able to use a less burdensome approach to determine their fuel consumption and CO2 emissions.

This simplified approach to monitoring is based on fuel consumption estimation tools, which generally utilise statistical information that relates fuel consumption to the distance flown. These tools must first be approved by the Commission before they can be used by small emitters for monitoring purposes.

On 9 July 2010 the Commission adopted a Regulation on the approval of a simplified tool developed by Eurocontrol to estimate the fuel consumption of certain small emitting aircraft operators developed by Eurocontrol. The tool is available on Eurocontrol's website.


EUROCONTROL - Small Emitters' Tool (http://www.eurocontrol.int/environment/public/standard_page/small_emitters.html)

[Mike Echo]

Hmmmm
Not sure what I was expecting after 6+ months as an approved tool, but this wasn't it.
Back to thinking
M.E.

[flyingfemme]

They took how long to develop that?

[Sepp]

I'd like to say "unbelievable" - but sadly, it isn't. :ugh:

[Mike Echo]

I'm beginning to doubt myself so I'll look at it again in a couple of days and after a few drinks. At one point I thought I understood what I was doing, :O now I really think I'm missing something beside brain cells. :confused::confused::confused::confused:
M.E

[mattman]

Ok so now I have used a greater circle +95km (why not 52nm is beyond me) plug it in and to my aircraft type and got fuel and emissions.
So far the year has produced a staggering 220 tons.
And now?
Must I get some aviation leech to confirm I can move data around a spread sheet.:uhoh:
I want to start buying co2 can anybody elaborate how we go about this. Going to buy some while cheap, hopefully will get a bonus for my forward thinking :} or sell to company with a margin added for myself, for is this not the idea:rolleyes:

[mattman]

And OMG as I post that a banner comes up with a advert for a emissions trading and consulting company:eek:
Big brother is watching.............:E

[Mike Echo]

Just curious if anybody has played around with this tool.
Having pulled up all our flights from February the fuel used came to around 20,000 kg. (Learjet 40 flight times from 1 to 4hrs europe and US)
Calculating the GC route distances+95km and plugging them into the tool gave a whopping 32,600 kg
I know it is just an estimate but a 60% difference (in their favour) seem excessive.
Hopefully I've made a computational error somewhere in the calculations but just wondered if anybody else has tried it?

M.E.

[mattman]

Mike Echo, I have the same calculations issues. the calculator has even stated on our long trips we burn more fuel than we can carry.:*

me thinks there is a rat amongst the pigeons. will be intresting to see what EBAA say about it.

Matt

[Mike Echo]

Mattman
Thanks, I was seriously doubting if I was doing all the conversions right.
I have passed on my spreadsheet to BBGA (and then to EBAA). Something is not right but not in our favour -- strange that:)

Out of interest I have also contacted the Environment Agency about how we are supposed to present the reports. Would I be be expecting too much if we could just report "We have used xxxxxx kg of fuel this year" !!!?
Back to my hole.

[Mike Echo]

Bombardier Operators.
It has been brought to my attention (yes, I know I should have seen it!:O) that Bombardier has issued a Communique BCSB Com 0309.

We are aware that a discrepancy exists in the fuel consumption and CO2 values for Bombardier aircraft when using the tool compared to the fuel consumption and emissions calculations determined by Bombardier and posted on the CIC website

They are working to resolve this.
M.E.

[4HolerPoler]

Dragged our heels as much as possible but finally have an approved plan. Whoop-dee-doo!!

Within two days of the approved plan skimming into the Inbox I have received another letter from these toss-pots informing me that:

"Dear Operator, As you may be aware you are required to open your Aviation account within the CSEUR (Union Registry)."

The reality of completing the onerous requirements to have an "Aircraft Operator Holding Account" is eye-watering. Full disclosure on the "Authorized Representatives" including a copy of my passport (all pages are required - are they mad? - I have a 50 page passport), a criminal record check, proof of permanent residential address (I don't have one, I'm a corporate aviator) and then the quirky Proof of Name requirement - the same 50 page passport will suffice. And I need a minimum of another "Authorized Representative" - the bureaucrats really have us bent over a barrel on this issue.

We're a corporate aviation department; have no interest in signing up to trade carbon credits - please tell me that there's someway around this - surely we can use Universal or Jet Aviation or the like to act as our proxy or appoint a trader to act on our behalf.

There have been many stumbling blocks on this seedy road but this is a big one; my corporate & legal folk are never going to go with this - any suggestions?

[Chinchilla.612]

4HolerPoler,

Firstly congrats on the approval for your monitoring plan. Just out of interest though, is that the old style monitoring plan or the new one which comes in from the end of July this year? I had an email from our incompetent authority to expect the new style forms to be available for completion online around the end of July.

Despite initially being allocated to Greece, just after we completed our first emissions report (after verification) the EU decided to change us over to Germany. With their very own way of completing everything and their own online only forms I was forced to restart the entire process from scratch with only one week left till the submission deadline. Got to love the way they disorganise everything!

I have been working on the holding account problem for a few months now with the German authority demanding all kinds of things as you describe there. Unfortunately a lot of what they request is simply not available from our country of operation so progress is particularly slow on this as I have to keep reverting to them in response to each of their suggestions. E.g. "no I have not been able to pursuade the government here to do xxxxxx just in order to satisfy your requirements, perhaps you could liaise through your embassy and see if you have more luck with this?"

The German response to our query about appointing a proxy or trader to complete this on our behalf was that it had to be done by the entity for whom the aircraft was recorded with EuroControl. So if your EuroControl bills go to Universal you're onto a winner.......if, like us, your EuroControl bills go to yourselves as the operator then not so much! Unless of course, the authority you are administered by has a different interpretation of the rules (as each member state is doing it their own way!).

If you come across an easier way to deal with all this nonsense please get in touch, and that goes for anyone else with tips to share too!

Finally, to put it into perspective - in 2011 we produced a grand total of 106 tonnes of CO2 within the trading scam area which was spread over a total of 17 afflicted flights............

[mutt]

Is the "small emitters tool" really an excel spreadsheet with 10 rows and 5 columns? If this is the case, then I'm extremely happy to know that the EC are not wasting our tax euros on worthless and time wasting fully functioning tools :):)

Mutt

[inbalance]

Small emitters tool: http://www.eurocontrol.int/sites/default/files/content/documents/single-sky/other/emission-calculator-2012-01-20-310m-released.xls

[PukinDog]

Dear Europe,

Thank you for saving the planet with paperwork, taxes, and a billion man-hours spent by those trying to avoid punishment if they don't comply with your decrees.

Without you, we were all doomed.

Love,

Dog

[Mike Echo]

I have had a lot of communications with the Eurocontrol Small Emitter people trying to get the figures for our aircraft (Learjet 40XR) correct.
Using the original tool we were using more fuel than our big brother Learjet 45XR
I found they just looked on the FAA website and found that the 40 and 45 had the same Type Certificate, the fact that the 40 is lighter and has no APU was not taken into account and they were lumped together. To give them their due they did eventually take this on board after I explained about Type Certificates and different models plus real figures from our flights. They basically did not know. It is now not great but much better than before.

For those coming under the UK you could try sending something to
Red Tape Challenge - Aviation (http://www.redtapechallenge.cabinetoffice.gov.uk/themehome/aviation/) or e-mail
[email protected]
Closes tomorrow (Thursday) but I only knew last week.

I did a couple of memos on ETS and EASA. They will have absolutely no effect, but after a rant and a cup of tea I felt better:):)

How to explain the Registry to our Financial Diretor and accounts is the next problem - still too far for retirement to be an option.

Mike Echo

[mutt]

Inbalance..... thank you, but thats what i downloaded, to me its an excel sheet with very few aircraft types, what am i missing?

Mutt

[Mike Echo]

Mutt
Nothing obvious
Just highlight and delete cells A3 to A 10 and B3 to B10 to blank the cells then enter your Type designator(eg B737, LJ40) in say A3 and the distance in B3 hit enter, it should fill in the rest of the line. Then add as many lines as you want. We only have one aircraft type to fill in.
It seems to have a hidden database of aircraft type designators.
At the end of a year I copy and paste the spreadsheet so I can actually use it but there are probably better ways.
Enjoy!

Mike Echo

[mutt]

Aha....... Makes sense..... Just glad that I don't have to deal with it...... :)

Mutt

[Daifly]

So, it's been suspended then for international operators:

EU Commission freezes EU carbon emissions law for airlines | Reuters (http://uk.reuters.com/article/2012/11/12/us-eu-airlines-ets-idUKBRE8AB0HB20121112)

That helps the industry no end...

[Steak&Kidney_Pie]

Finally some common sense prevails. Apparently will be reintroduced in one year if ICAO do not come up with a global emissions solution.....:mad:

Once again, in the EU, then get penalised for it!

[Daifly]

It does seem like yet another knife in the back for us all in Europe.

It will be nice to know that non-EU operators will be able to fly around in Europe (obviously fully obeying cabotage requirements) not incurring the charge though, making us all even less competitive...

Will be interesting to see what happens come November 2013, I suspect ICAO won't have done anything and imagine it will get extended again.

[Fossy]

Daifly, your statement is not completly right. The ETS will be charged to all airlines for flights taking place in the EU. No charges for the flights from and to the EU


The European Union will put on hold its rule that all airlines must pay for their emissions on flights to and from Europe

[Daifly]

Maybe it's just bad journalism (or unclear legislation!) but the next line reads: EU airlines will still have to pay for their carbon emissions under existing rules and EU member states will still have to formally endorse the Commission's exemption for non-EU carriers, Hedegaard said.

[densityaltitude]

Wonder how much carbon has been generated by humans discussing this scheme.

[mattman]

Not so fast, firstly it has to be ratified by all 27 EU States, and it does not apply to inter EU flights, ops normal according to them. See below press release from Universal.

I don't believe this will go ahead as EU states will see it as anti competitive to EU airlines.
Miss Hedergard is trying to back peddle but still not enough as she is trying to safe face, no EU State is brave enough to impound a Chinese airliner for not complying.

Mexican standoff methinks!




Today’s press release by the European Commission (EC) (attached) and subsequent new material include a lot of information and statements regarding EU-ETS that should be reviewed carefully.

The EU Commissioner for Climate Action, Connie Hedegaard, has shown through her statement a willingness by the EC to compromise with respect to EU-ETS requirements for Aviation Activities that occurred during the 2012 monitoring year. The proposal that Commissioner Hedegaard has recommended via conference call, would remove the requirement for operators to Monitor, Report, and Verify CO2 emissions and Surrender Carbon Allowances for international flights to or from the EU (i.e. KTEB-EGGW), but maintains that all current obligations for any operations within the EU (ie. EGGW-LFPB) remain intact.

There are three important items to note regarding this “Stop the Clock” proposal:

1. This proposal would have to be ratified by all 27 EU Member States to become effective

2. All operators are still responsible for Monitoring, Reporting, and Verifying CO2 emissions for intra-EU activity, and surrendering the appropriate amount of Carbon Allowances by current posted deadlines

3. It is only a temporary measure to “create a positive atmosphere” around the negotiations with ICAO, to create a global greenhouse gas reduction scheme and not a permanent change to the EC Directive

In summary, the international aviation community must continue to prepare for compliance with EU-ETS as presently constituted until an official resolution is reached regarding this proposal or any other proposal of its nature.

If this proposed measure were to be implemented, operators would still be responsible for all phases of EU-ETS for intra-EU activity. To comply with these regulations, operators need to have systems and procedures in place to Monitor, Report, and Verify CO2 emissions, and surrender Carbon Allowances. Establishing a Carbon Registry/Aircraft Operator Holding Account to bank and surrender allowances should still be the top priority for operators captured by the scheme.

[mattman]

So now President Obama has signed it into Law.

What is the implication for N reg opertors and what are they doing now? Can you just stop with all the ETS rubbish or do you still comply?:rolleyes:




The National Business Aviation Association issued the following news release:

The National Business Aviation Association (NBAA) today thanked President Barack Obama and members of both houses of Congress for their work in passing the European Union Emissions Trading Scheme (EU-ETS) Prohibition Act.

President Obama signed the measure (S. 1956) into law today.

"With final passage of this act, the president and Congress stand as one in declaring that the EU-ETS is an overreach, it's wrong and it won't fly with operators based here in the United States," said NBAA President and CEO Ed Bolen. "This is an issue that should rightfully be decided within the framework of the International Civil Aviation Organization (ICAO). With passage of this measure, the United States government has said with clarity and conviction that it will stand in favor of international law and against the unilateral imposition of one region's will upon the rest of the world."

EU-ETS was unilaterally imposed on the aviation industry by the 27 member states of the European Union as a market-based solution to greenhouse gas emissions. Aviation operators were to have begun purchasing carbon credits for exchange on the open market by the end of April 2013. It was estimated that EU-ETS would cost the U.S. aviation industry $3.1 billion and thousands of jobs over the next decade.

Final passage of S. 1956 comes just a few weeks after EU Climate Commissioner Connie Hedegaard announced the planned suspension of EU-ETS enforcement on operators based outside of Europe. Hedegaard said she was encouraged by what she viewed as solid progress made on development of a market-based emissions control system during a Nov.9 ICAO summit.

"Together, NBAA views these developments as extremely positive for our industry here in the U.S. and for aviation cooperation worldwide," Bolen said.

[NuName]

Anyone else get this in their email?

"EU ETS Compliance Deadline 31st March 2013 - ETS.aero Introduction and Brochure"

[dc9-32]

How does this affect biz jet operators ?

[Mike Echo]

The way I'm understanding this,
1) The EU suspension for 12 months will make almost no difference to Biz-Jet operators. You only save on the into and out of sectors all the others inside the member states still have to be accounted for. For us this is only about 6 sectors a year (BIKF-CYYR) In some ways this has complicated matters as these have to be removed. However, if the Suspension is lifted next year then you will still have to pay for these sectors. What this has done is lift the international airlines out of the scheme for a year and maybe reduce some of the pressure on the EU.

2) EU-ETS Prohibition Act --S. 1956 would direct the Secretary of Transportation to prohibit an operator of a civil aircraft of the United States from participating in the European Union’s emissions trading scheme in any case in which the Secretary determines the prohibition to be in the public interest, and would also provide the Secretary of Transportation with the authority to ensure that U.S. aircraft operators are not penalized or harmed by the E.U.’s unilateral emissions trading scheme.

This is where I can see the Biz-Jet (N reg) operators getting between a "rock and a hard place". Much as I dislike the thought, the EU countries do have the right to legislate on what happens in their airspace and could ban or impound aircraft if the Operater does not comply within the EU. Whether
the US Secretary of Transportation would bring trade sanctions and finance to help a lone Operator I seriously doubt. Hopefully, some clarification can be obtained from NBAA as I just cannot work out how all this would be enforced.

Mattman has encompassed most of the options.

Anybody any other thoughs?

M.E.

[Booglebox]

The above posters seem to have got it spot on :cool:
I recently had a chance to quiz BA's environment chap about this - he said that the ETS suspension is so that the ICAO meeting in October next year can come up with a workable solution.
If not, ETS will be re-introduced in some form, apparently.

Mike Echo: we also discussed the situation with the Chinese and US airlines refusing to comply, and he agreed with my suggestion that, obviously, any scheme where there is widespread dissent and disobedience is unworkable; you can't ban / impound every non-EU airline / aircraft for something like this.

If ETS is re-introduced, it looks like it will be intra-EU only, for the time being, as a first step. Otherwise, it will defer to ICAO. :}

[nje1md]

Just a thought - as far as I am aware - the Channel Islands are outside EU-ETS.

Is there any margin on longer EU sectors out of the UK / Ireland or say from Northern Europe en route Spain/Portugal to make a quick techstop at Guernsey or Jersey so that the flight is split into two sectors from and to a non EU-ETS airport?

[mattman]

Just a warning to one man band'ers that are struggling with the paperwork, don't remove those international flights just yet. EU States have to ratify Mrs Hedergaards plan to pacify. Now apparently there is a backlash from the local airlines that this is a little unfair.
Either way, your going to end up having to do the grunt work paper wise and play ETS trader later.

Man I wish I could just fly.

[Mike Echo]

NJE1MD - I'm probably wrong but I suspect with the longest sector in the EU to be around 4 hrs there would be no advantage in stopping in the Channel Isles. I haven't done the sums but the additional cost of handling etc may offset any savings in the EU-ETS charges/tax.

mattman - I learnt a long time ago not to throw away/delete anything. I'm just keeping my head down and doing all the recording. I would be amazed if all 27 Countries agreed.

My biggest worry is what may happen with N reg operators when the US sorts out the regulation banning us from taking part.
M.E.

[cambioso]

Do you mean there really are people that ARE actually paying it????

[mattman]

I have to ask who has finished with this cr@p and surrendered there cO2.

Just had a real heated argument with out national authority telling me to return 4 of my free allowances (only four at current market rates €12.00) in a given deadline but they need 12 working days to achieve this but the deadline is the 30th April.

Anybody else had similar results.:rolleyes:

[4HolerPoler]

I've resisted this scheme (dragged kicking & screaming) but did the bare essential to remain in compliance.

We had our plan approved, then they told us we needed to become carbon traders. That was a show-stopper (we're an aviation op, not into trading carbon credits and the dislosure requirements are cumbersome & invasive); despite some resistance and opposition we were able to appoint a proxy to conduct the carbon trading on our behalf.

No credits (we still had our heels dug in), we've adopted the derogation stance (only report inter-European sectors). We got the verification done about a month back and conducted a spot-trade on the purchase of our assessed EUA's (a couple of hundred) due for 2012 recently. So I see us as having done enough to keep these bureaucratic clowns at bay.

We're a Private US-registered global operation that was assigned the UK (we spend quite a bit of time there) for EU-ETS purposes.

I still maintain that it's a giant crock of sh1te however that in itself is not a reason not to be in compliance. My dealings with the ETS folk have clearly shown them to be a crowd of sanctamonious creeps (they send you a bill to cover their operating expenses) - I could imagine nothing worse than to deal with them if they were able to show that you were not in compliance with this ridiculous scheme.

4HP

[Opsbeatch]

It is indeed a farce, every time they give you a hoop to jump through they replace it with a brick wall!

I have had rows with the EU directly about this and can only see it as a job creation scheme with all types of scum ready to relieve you of any money. My solution? Just put 3 cag on fuel across Europe as an EU tax, this would pay for the frog huggers to have a new nylon carpet installed in Brussels...!

OB

[navstar1]

Overall a total nightmare! Opening an aircraft operating account is even worse. I have never had to provide such detailed confidential information to any authority having been in the industry for 35 years (guess which country we have been allocated:(). Only have about 6 flights to the EU each year(totally private). Time to retire good luck to those who remain you are going to need it:sad:

[I.R.PIRATE]

Same boat as you 4HP. Heels firmly dug in while we wait for the inevitable. But it seems that once they have your number, they are pretty tenacious...

..even the boss is starting to reconsider his business interests in the UK, what with APD, ETS and the downward spiral we are experiencing with customs and immigration these days.

10-12 private trips to or via the EU and also been dealt a UK 'base'

Way too much bull**** information to be filled in on the registration - nothing that is a single iota of business of these ETS mongers

:(

[His dudeness]

Man I wish I could just fly.

You are sooooo right. I can´t stand that bloody sh1te any more.

Does anyone remember, say, 1990? Where you would drive to the airport, file a flightplan (the same you had filed the last 5 years) hop on the plane and go.

No IFPS/CFMU, no out-of-control-security, no airport slots, no APD, no CO2 terror, no new rules every fortnight etcetc.

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