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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. 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: |
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. |
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? |
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 |
FMOB I got approved, now to see if my made up b/s system will work when they want my first report!
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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. |
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. |
All of us "small" operators should get together...
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 |
Think the same is going to happen in aviation? You bet your sweet @rse it is! |
EU ETS Aviation emissions
Has anyone actually been served with a "civil penalty" yet for refusing/failing to file their application for an emissions plan?
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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 |
"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". |
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 |
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. |
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?! |
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.
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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. |
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 |
EU-ETS exemptions....
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 |
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 |
@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 |
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. |
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 |
Hmmmm
Not sure what I was expecting after 6+ months as an approved tool, but this wasn't it. Back to thinking M.E. |
They took how long to develop that?
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I'd like to say "unbelievable" - but sadly, it isn't. :ugh:
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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 |
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: |
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 |
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. |
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 |
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. |
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. |
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)." 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? |
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............ |
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 |
Small emitters tool: http://www.eurocontrol.int/sites/def...m-released.xls
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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 |
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 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 |
Inbalance..... thank you, but thats what i downloaded, to me its an excel sheet with very few aircraft types, what am i missing?
Mutt |
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