European Union Emissions Trading Scheme (ETS)
 

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

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

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

Wake up muppets...:hmm:

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

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.

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

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.

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/clim...ors_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

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.

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.

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:

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! :}

...oh, that wasn't so hard after all...
 

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:

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.

'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/viewfil...pdf&filetype=4

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

and the exemptions are right at the end :
In other words; anything that does not currently attract Eurocontrol will be exempt as will "small airlines".

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!

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.

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.

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.

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

Guidance for the Aviation Industry
http://www.environment-agency.gov.uk...1.0_280509.pdf


ANNUAL EMISSIONS MONITORING PLAN
http://www.environment-agency.gov.uk..._operator).pdf

TONNE-KILOMETRE MONITORING PLAN
http://www.environment-agency.gov.uk...n_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/clim...008/10.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

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....

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

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. :)

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.

Annual Emission Monitoring Plans now complete everyone?
 

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:

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

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

Well, searching on internet I found this

http://www.environment-agency.gov.uk...siness/FAQ.pdf

Subject 3

Flow Chart
 

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

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.

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.

+ 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.

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!

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).

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.

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?

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. :{

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.

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.

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.