With less than four months to go before the March 31 deadline for aircraft operators to submit independently verified emissions reports for the European Union Emissions Trading Scheme (EU-ETS), there is still widespread confusion as to how the verification process will work for many in the business aviation sector. European authorities continue to be slow in approving the independent verification companies needed to complete the task and the industry is still awaiting a final European Commission ruling as to whether costly site visits will be required to complete verification for the so-called smaller emitters.

What is clear is that all operators assigned to an EU state for ETS compliance purposes (regardless of whether they are based in the EU) have to file a verified emissions report for 2010–regardless of whether or not they are claiming free carbon credits for 2012, when the full ETS implementation begins. In the October edition of AIN (“Confusion reigns over ETS implementation in Europe,” page 6), it was incorrectly reported that only operators claiming credits need to complete this task. Those claiming credits also have to file the so-called “tonne-kilometer” report, calculated from the number of metric tons of fuel burned, the number of kilometers flown within EU airspace over a Great Circle route (plus 95 nm) and the payload flown.

According to Neil Duffy, technical manager with UK-based verifier ICM ETS, questions as to whether site visits are required will probably be resolved only when the European Commission (EC) approves the final version of Eurocontrol’s ETS Support Facility (covering the process for small emitters). This has been expected for many months and should be issued before year-end. According to sources close to the approval process, the delay has been caused by disagreement over how much, if anything, to charge operators to use the facility.

The final version of the support facility will go live next month, according to Bo Redeborn, director of cooperative network design with Eurocontrol. On November 10, he told Quaynote’s Future of Business Jets conference in London that it would cost operators €400 per year to subscribe to the tool. This fee will allow them or their authorized verifier access to flight data, which will be archived for 10 years.

Eurocontrol has been adding new aircraft manufacturer data to the support facility to improve the accuracy of emissions calculations, which have been found to be significantly inaccurate for some aircraft types in early use of the beta test model of the system.

According to the UK Environment Agency, which has been one of the more transparent EU ETS authorities, the EC is about to give a final ruling as to whether site visits will be required. Its Web site (www.environment-agency.gov.uk) points out that the broad EU guidelines say no more than that a site visit “may be appropriate” but there is no information as to the circumstances in which it may not be required. This decision alone could make a big difference to small operators facing EU ETS compliance costs that they feel are in danger of being out of proportion to their actual carbon footprint.

What’s more, the actual cost of EU-ETS compliance will vary significantly depending on which EU national body an operator has been assigned to. Some countries are charging little or nothing to file emissions reports. The UK is charging approximately £800 ($1,280) for the annual emissions report and the same again for operators completing a tonne-kilometer report to claim free carbon credits (prompting some small operators not to bother claiming these).

Meanwhile, the European Business Aviation Association (EBAA) is continuing to push for an increase in the threshold at which operators can be categorized as small emitters for ETS compliance purposes. It currently stands at 10,000 metric tons of CO2 per year, but the group has argued that the Eurocontrol data in the ETS Support Facility is sufficiently accurate to justify increasing this to 25,000 or even 50,000 metric tons.

Eurocontrol estimates that approximately 3,000 operators can currently be classed as smaller emitters, but this number would increase if the CO2 emissions threshold were raised. This in turn could reduce the cost of using the ETS Support Facility.

According to EBAA, even the EC’s updated list of operators subject to ETS is full of inconsistencies and errors. Partly due to the complexity of the compliance process, it maintains that as many as 30 percent of those operators who should already have registered for ETS have yet to do so.