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Topics: Emission Trading System
Organisations: EBAA

Emission Trading Airlines

Mrs Satu HASSI Member of the European Parliament Committee on the Environment, Public Health and Food Safety Bât. Altiero Spinelli

08G351

60, rue Wiertz B-1047 Brussels atu.hassi@europarl.europa.eu

26 February 2014

Dear Mrs Hassi,

ON-GOING REVISION OF DIRECTIVE 2003/87/EC At the February meeting of the Council for Environmentally Friendly Aviation (CEFA), the undersigned Associations considered the on-going revision of the EU ETS legislation (Directive 2003/87/EC). Without prejudice to the respective positions of individual stakeholders on other aspects of the proposed revision of Directive 2003/87/EC, this letter includes the collective, and agreed, views of the undersigned Associations on a number of issues under discussion by the legislators in the European Parliament, Council and Commission. I hope that they will be helpful during the on-going negotiations to determine the final text of the legislation. The need for legal certainty The legal uncertainty to operators caused by the current debates and the possibility to provide legal certainty only until 2016 is a cause for concern. Operators need business and legal certainty to enable mid and long-term operating, financial and investment plans. Hypothecation of auctioning revenues The undersigned Associations support any revision to the Directive aimed at hypothecating auctioning revenues from the ETS and any earmarking of these revenues for investment in aviation-related projects and research & development aimed at emission reductions. Enforcement and application of the legislation Equal enforcement and application of the Directive on European and third country carriers is essential for its fair application and to ensure the basic principles of non-discrimination and equal treatment are met. As such, the undersigned Associations wish to see the active and robust enforcement of the final legislation by member States on all carriers. Applicability of the legislation to third country carriers Whatever the outcome of the discussions on the scope of the final legislation, the undersigned Associations could only accept exemptions from the EU ETS for third country carriers based on de minimis clauses if this provision would not distort competition on intra-EEA networks. Amendments to the cap The undersigned Associations understand from various statements that a possible amendment to the overall emissions cap is being considered as a means of compensating for any amendment to the scope of the EU ETS. Such a change would substantially penalise European operators. Furthermore any proposal for a change to the cap would need to be accompanied with a detailed impact assessment. In consideration of the above, the undersigned Associations seek your support to consider these positions and concerns during the trilogue negotiations.

For further information please contact:

Association of European Airlines (AEA)

Athar Husain Khan, Chief Executive Officer, Tel. +32 2 639 89 89 Email: athar.husainKhan@aea.be

European Business Aviation Association (EBAA)

Fabio Gamba, Chief Executive Officer, Tel. +32 2 766 00 70 Email: fgamba@ebaa.org

European Low Fares Airline Association (ELFAA):

John Hanlon, Secretary General, Tel: +32 2 504 9005 Email: john.hanlon@elfaa.com

European Regions Airline Association (ERA):

Simon McNamara, Director General, Tel: +44 1276 856495 Email: simon.mcnamara@eraa.org

Document Info

  • Language: en
  • Created: February 26, 2014 3:23 PM
  • Last Modified: February 26, 2014 3:23 PM
  • Pages: 2
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  • SHA1 Hash: a6d30616105fb39861f82f891f12d395c414d642