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Topics: Emission Trading System
Organisations: ELFAA

Airlines Emission Trading

European Low Fares Airline Association

46 Avenue des Arts

B-1000 Brussels


tel: +32 (0)2 504 90 05

fax: +32 (0)2 732 71 76 - -

Registered address: 21-23, 1


Floor, West Street, Oundle, Cambridgeshire, PE8 4EJ, United Kingdom

Registered in England & Wales No. 5882574

Mrs Satu Hassi Member of the Environment Committee European Parliament Rue Wiertz Brussels By Email

17 March 2014

ELFAA urges rejection of environmentally-ineffective compromise on EU ETS

Dear Mrs Hassi,

The European Low Fares Airline Association (ELFAA) has consistently supported the

inclusion of aviation in EU ETS. We acknowledge that aviation’s emissions of CO2, if

mall in relative terms, are nonetheless material and there is a need in the short to medium term for a properly-designed Market-Based Mechanism, to supplement other technological measures. It is clearly vital, however, that any MBM be environmentally effective. 80% of EU

aviation’s emissions of CO2 being from long distance flights, this necessarily means the

inclusion of all flights to and from the EU.

ELFAA offered its support to the EU’s defence of the legal challenge to the all flights

cope, brought by the US carriers, and was pleased that the CJEU, in upholding the legality of the scheme, as specified in the Directive, further observed that it would be discriminatory to exempt flights by destination/origin and, further, contravene the environmental objectives of the Directive, as stated in the preamble.

In supporting the Commission’s flawed “Stop the Clock” exemption of

flights to and from

non-EEA airports, from compliance in respect of 2012 emissions, your Committee made very clear that your support was conditional on the Derogation being for one year only. Your committee further made clear its view that any extension would represent discrimination, against intra-EU/EEA operators and their customers, unacceptable to your committee.

tel: +32 (0)2 504 90 05

fax: +32 (0)2 732 71 76 - -

Registered address: 21-23, 1


Floor, West Street, Oundle, Cambridgeshire, PE8 4EJ, United Kingdom

Registered in England & Wales No. 5882574

Despite the 2013 ICAO delivering neither of the explicit conditions on which the 2012 Derogation was predicated, we now have the unseemly spectacle of states, for reasons

which have nothing whatever to do with the environment, clamouring to extend the “one year only” conditional 2012 Derogation. Those states baying for extension of “Stop the Clock” have made clear their preference for it to extend to 2020, seeking to “justify” this by enabling “progress” at ICAO to continue. The ICAO Working Group has meanwhile

met, but - if I am correctly informed - without the presence of any of the members of the group, representing the dissenting BRIC states. It is highly likely that the 2016 ICAO General Assembly will yield no more positive outcome than the weak Resolution, passed at the 2013 Assembly, which differed hardly at all from that passed in 2010. It would appear that the Council also has little faith in any solution being to hand at the 2016 Assembly as evidenced by their proposal to extend STC to 2020.

Council, Parliament, and Commission having, at taxpayers’ expense, successfully defended the EU’s legislative prerogative to apply the ETS Directive to

all flights, coming

within EU jurisdiction by choosing to land at EU airports, have meanwhile surrendered this confirmed legal right once already, but to no useful avail, in the form of the 2012 Derogation. Parliament is now being asked to repeat this futile concession for 4 more years, for no real environmental gain, now or in the future, but constituting real discrimination against EU industry and European c

onsumers’ interest.












environmentally-ineffective compromise which the trialogue recommendation represents.

Yours sincerely,

John Hanlon Secretary General European Low Fares Airline Association

Document Info

  • Title: 30th April 2007
  • Language: en
  • Author: Maria Borg
  • Created: March 18, 2014 1:11 PM
  • Last Modified: March 18, 2014 1:11 PM
  • Pages: 2
  • Encrypted: No
  • Dimensions: 595.32 × 841.92
  • Filesize: 115.38 KB
  • SHA1 Hash: 6d2a2fbf61998ce1fc91b39a8d9604b30e19b72b