The business aviation community has long been committed to reducing its environmental impact and we have improved the fuel efficiency of our aircraft by 40 per cent over the past 40 years. Looking ahead, our commitments parallel those of the airline sector and we pledge an average of two per cent improvement in fuel efficiency per year from now until 2020 on a fleet-wide basis. We also recognise market-based measures as an essential, if small part of our global business aviation strategy to achieve our stated 2020 goal.

However, in an earlier column (December 2009) I drew attention to the ongoing problems with the practical application of EU-ETS to aviation and, in particular, to the difficulties so many small corporate operators are experiencing, because of the decision to set a de minimis threshold of 10,000 tonnes of CO2 emissions for commercial operators, but no such baseline for non-commercial operators. In consequence, we forecast that the system would prove disproportionate and unworkable, and now the accuracy of our position is being confirmed by official figures.

The European Commission publishes a list of operators assigned to each EU member state, but the list published earlier this month, like all previous ones, is full of inconsistencies and errors. The main problem is that a large number of operators are still identified by service provider designation and not by name. Many operators should not be on the list at all, while the time to register operators varies hugely by operator and member state. To confirm the muddle, the UK department for transport has advised that over 250 operators' ETS emissions plans have been approved, with another 100 in progress from a total UK list of 894 operators. But 341 (38 per cent) remain unaccounted for and potentially not compliant with this mandatory element of the ETS scheme. Yet this 38 per cent account for less than one per cent of the UK's aviation emissions, proving the absurdity of the scheme, particularly for small non-commercial operators, many of whom emit only a few tonnes of "eligible" CO2. Moreover, even those small emitters that are rightly in the scheme, as yet have no "simplified tool" to help them calculate their liabilities.

To help resolve this mess the EBAA is committed to two main objectives: in the short term, we are pressing hard to get the EU-ETS Support Facility up and running despite the political difficulties of such a scheme being run by Eurocontrol. This will then allow small emitters to have their emissions independently calculated without the need for expensive independent verification.

In addition, we are asking the European Commission to raise the small emitter reporting threshold from the current 10,000 tonnes to as high as the accuracy of the system allows. We hope, if it is within plus or minus two per cent, that this will be as high as 500,000 tonnes, so that EU-ETS does not become a consultants' bonanza. In the longer term, we want to see the Framework ETS Directive exemption threshold for non-commercial operators raised to the same level as commercial operators (up to 10,000 tonnes of CO2). This will eliminate the current absurd levels of bureaucracy and nugatory costs on subjects and regulator alike managing those that emit virtually nothing, while ensuring that those above a sensible threshold rightly pay for their emissions in a manageable way. Then, and only then, will we have a workable system that can be supported by all stakeholders!

By Brian Humphries, president European Business Aviation Association (EBAA).