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Within the last few weeks the global business aviation operating and manufacturing communities have come together to issue a joint position, re-asserting our support for the International Civil Aviation Organization's (ICAO) proposal for aviation sectoral management of targets and monitoring of greenhouse gas emissions in a post-Kyoto agreement.
This is something of a landmark achievement, as it is the first time the whole of our community has come together to develop a common position on this very important issue for us all.
Of course, as most readers will know, business aviation has established an excellent record of consistently improving fuel efficiency, delivering 40 per cent improvement over the past 40 years. Indeed, our CO2 emissions in Europe are less than one per cent of aviation emissions and globally our sector contributes less than .04 per cent of man-made carbon emissions, so by no stretch of the imagination are we significant polluters. Nonetheless, our community is resolved to do even more and we have jointly developed an aggressive programme in support of ICAO targets committing to:
Achieving these targets will require not only sustained effort on the part of the entire business aviation community, but also a partnership between industry and government, and the development of realistic solutions that balance economic growth, progress and technology. We plan to achieve these objectives through expected advances in four areas: technology, infrastructure and operational improvements, alternative fuels, and market-based measures. Meanwhile, consistent with ICAO recommendations, business aviation supports the development of an appropriate alternative metric to measure and track business aviation emissions on a fleet basis, in place of the inappropriate airline oriented T-K performance indicator. This is not relevant to our operations, where we sell the "whole plane" and therefore have no control whatever over passenger loads, in sharp contrast to the airlines which sell seats and so are in full control of load factors. Moreover, given the global nature of aviation, internationally harmonized policies, rules and procedures are critical to ensure safe, efficient and balanced operations, which is why our community believes that ICAO must be assigned global sectoral responsibility over aviation emission targets and monitoring.
To emphasise the rightness of this policy we need look no further than the ongoing problems with EU-ETS' application to aviation and, in particular, all the difficulties so many small corporate operators are experiencing with compliance. We have long supported the development of the Eurocontrol ETS support facility designed specifically to ease the task of small operators in meeting their compliance obligations with the minimum of bureaucracy and cost. Well, despite the specific commitment by the European Commission in the monitoring and reporting guidelines issued in April: "Aircraft operators that are small emitters may estimate the fuel consumption using tools implemented by Eurocontrol or another relevant organisation, which can process all relevant air traffic information such as that available to Eurocontrol."
After all the efforts by EBAA to support the ETS support facility as an essential tool for small emitters, at its meeting in October the Eurocontrol Air Navigation Services Board delayed the adoption of Eurocontrol's proposals to continue its development as a service to users. At the very least this is likely to delay the set up of the ETS support facility by three months and we are concerned at the impact this will have on the thousands of small emitter operators that are planning to use it to meet their MRV obligations in accordance with the ETS Directive. Indeed, a very large number of small emitters have already declared to their allocated national competent authorities that they will be using this simplified procedure.
According to Eurocontrol's data, there are more than 3,000 small emitters captured in the scope of the ETS directive, all of which could potentially become users of the MRV simplified procedure. Additionally, the European Commission, as noted in the extract above from the Commission Decision on MRV guidance for aviation, is committed to ensuring that Eurocontrol provides a simplified procedure for small emitters. We also understand that many national competent authorities will need to rely on the ETS Support Facility to fulfill their oversight obligations.
For all these reasons we believe it is essential that Eurocontrol finalises the set up of its support facility and DG Environment validates it within the shortest time-line and we are shortly meeting with DG Environment to discuss the way ahead here. So once again with EU-ETS, it is one step forward and one step back.
As the Eurocontrol monthly figures show, business aviation activity levels in Europe continue to bump along the bottom and it is vital that we do not introduce yet more costly, bureaucratic and ill-thought out environmental rules to hinder the recovery. That is most definitely not to say that business aviation does not recognise the importance of meeting its environmental responsibilities as I have set out above. Quite the contrary, business aviation cares about the environment, but we believe strongly that fragmented national or regional ETS schemes are not the best way of delivering improvements and benefitting European citizens. How much better it will be if scope is given to the aviation community as a whole to manage environmental stewardship into the future, along with industry partners and under the leadership of ICAO. Let's all keep our fingers crossed that the right decision is made at Copenhagen.
By Brian Humphries, president European Business Aviation Association (EBAA).
