The European Business Aviation Association (EBAA) continues to protest that there should be a de minimis level of activity before business aviation operators fall under the requirements of the European Union Emissions Trading Scheme (EU-ETS), due to the disproportionate costs involved and despite their ability to use Eurocontrol’s ETS Support Facility (SF) for calculating fuel-use by so-called “small emitters.”

Armando Cairoli, an analyst in Eurocontrol’s ETS SF, told delegates at the second Isle of Man aviation conference on June 21 that 21 of the 31 competent authorities handling operators in the ETS have signed up to allow the Eurocontrol support facility to be used, benefitting more than 5,000 operators as it stands. Operators will get two reports in each period: a flight details report and a draft annual emissions report, he said. The first is a list that operators can check to ensure, for example, that they are not to be charged for exempted flights such as those en route to or from maintenance. Cairoli said that Eurocontrol “plans to give users access by the end of the summer, around September, so that is the time to cross-check.” The advantage, he added, is that “you can anticipate issues that the competent authority or verifier may raise.”

Eurocontrol’s Small Emitters Tool (SET) for calculating fuel use is currently available only to operators that generate no more than 10,000 tons of CO2 a year, “but this is expected to go to 25,000 tons,” said Cairoli, “or fewer than 243 flights in all of the four-month periods of January to April, May to August and September to December.” In fact, the ceiling was increased to 25,000 tons, after “a lot of lobbying,” according to EBAA president Brian Humphries. All operators need to do is state in their monitoring plans that they report using the SET and the ETS SF, which has a €400 annual fee for its service. Operators are welcome to contact the Support Facility at contract.office.ets.sf@eurocontrol.int, said Cairoli, who added that additional, recalculated reports would be free.

Humphries, also speaking at the Isle of Man conference, described ETS as “the worst bit of regulation I’ve ever seen, although I am not against market-based measures [in general].” He later described it as “a mess” and pointed out that while business aviation represents 7 percent of European IFR traffic it produces “less than one percent of the emissions and only 0.04 percent of total man-made emissions.”

Business aviation, he continued, has committed itself to achieving carbon neutrality by 2020, a fuel-efficiency increase of 2 percent in that time, 5 percent more than the airlines. “EU ETS is not fair on us; ton-km doesn’t work as a measure and the 85-percent free permits don’t apply to business aviation due to its being based on ton-km per passenger.”

Humphries continued that small operators are being hit disproportionately hard and for them “monitoring and verification costs are horrible.” He added that non-commercial operators are charged in the scheme; “as soon as they make one flight into Europe they have to do all the [ETS-associated] work.” This is for any aircraft that has a maximum certified takeoff weight of more than 5,700 kg/12,566 pounds. “So the real unfairness is that for us there is no threshold!”

For commercial operators it is two flights a weekday, effectively, or 10,000 tons of CO2 a year, before they have to report and pay into the ETS.

Humphries said that EBAA is also campaigning for another increase in the level where SF SET can be used, to 50,000 tons of CO2 annually. At the same time, he again underscored that “3,600 aircraft are being monitored by Eurocontrol in the EU-ETS and they emit only a few tons each.”