EU Aviation Giants Slam Proposed Non-CO2 Emissions Exclusion as “Absurd” and Potentially Illegal

In a strongly-worded joint letter, leading European low-cost airlines easyJet, Ryanair, and WizzAir have voiced  opposition to the proposed exclusion of extra-European Economic Area (extra-EEA) routes from the European Union’s non-CO2 Monitoring, Reporting, and Verification (MRV) system. The airlines argue that such an exclusion would significantly undermine the scientific value of the MRV and potentially breach EU law.

Understanding the MRV System

The MRV system is a critical tool designed by the European Union to gather data on the non-carbon dioxide (non-CO2) effects of aviation. These effects include contrails, nitrogen oxides (NOx), sulphur dioxide (SO2), water vapour, and other emissions like soot and aerosols. While the impact of CO2 emissions is well-documented, the non-CO2 effects are less understood but are believed to contribute significantly to global warming. The MRV aims to advance scientific knowledge in this area by collecting comprehensive data from the aviation sector.

However, the proposed exclusion of extra-EEA routes has sparked controversy. The airlines argue that this would create a misleading impression that long-haul flights, which are suspected to generate the most significant non-CO2 effects, have no impact. This could misdirect future mitigation measures and damage the aviation sector’s reputation, which is already under scrutiny for its environmental impact.

Key Concerns and Proposals

The airlines highlight several key concerns with the proposed exclusion of extra-EEA routes:

  1. Scientific Integrity: Excluding long-haul routes, which are suspected to contribute significantly to non-CO2 effects, would drastically undermine the scientific validity of the MRV. The airlines emphasise that a comprehensive dataset, including short and long-haul flights, is essential for accurately assessing and mitigating non-CO2 impacts. Intra-EEA flights account for an estimated 25% of European aviation’s carbon emissions, while extra-EEA/long-haul routes account for the remaining 75%. The skew towards long-haul routes is even greater for non-CO2 effects due to factors like flight altitude and timing.
  2. Legal and Diplomatic Implications: The letter warns that a blanket exclusion of extra-EEA routes could breach EU co-decision procedures and create a misleading impression that these routes have no non-CO2 warming effects. The airlines argue that this could misdirect future mitigation measures and damage the aviation sector’s reputation. They also note that international airline associations have been coordinating communication activities to ensure that non-EU governments are aware of the EU’s proposal and have been openly rejecting the legally-agreed extra-EEA portion of the scope
  3. Market Distortions: The airlines highlight that EU carriers already report carbon emissions for extra-EEA routes, and there is no clear reason why the same principle should not apply to non-CO2 emissions. They argue that this approach would not create market distortions since it is a reporting requirement, not a pricing mechanism.
  4. Extraterritoriality Concerns: While acknowledging concerns about extraterritorial impacts on non-EU carriers, the airlines propose a phased approach. They suggest that non-EU carriers initially report non-CO2 emissions for intra-EEA routes, with extra-EEA reporting being voluntary in the initial phase. This would ensure that real data is submitted for a significant portion of Europe’s long-haul network, enabling the science on non-CO2 to progress.
  5. Reputation and Public Perception: The letter stresses that the aviation industry is already negatively portrayed in the media and public eye due to perceptions of evading climate action. Excluding long-haul routes from the MRV could further damage the industry’s reputation and undermine efforts to present a unified front in tackling climate change.

Proposed Solutions

  1. Full scope for EU carriers: The signatory airlines propose that EU carriers should continue to report non-CO2 emissions for both intra-EEA and extra-EEA routes. For non-EU carriers, reporting could initially be voluntary for extra-EEA routes, with guidance to Member States to temporarily delay enforcement. This phased approach would ensure that real data is submitted for a significant portion of Europe’s long-haul network. The airlines argue that this approach would not create market distortions since it is a reporting requirement, not a pricing mechanism.
  2. Default Values: The MRV includes default values that can be used in the absence of submitted data. The airlines suggest that these default values should be applied if non-EU carriers do not submit data for extra-EEA routes. This approach would provide a broadly accurate picture of non-CO2 effects and incentivise data submission. The use of default values ensures that the MRV can still generate meaningful data even if some airlines do not participate fully.

Implications for the Aviation Industry

The joint letter underscores key divisions within the airline industry on sustainability issues. The co-signers argue that limiting the MRV to intra-EEA flights would make the system blind to the majority of non-CO2 effects, undermining its purpose and statistical validity. They stress the importance of a comprehensive approach to ensure that mitigation measures are correctly applied in the future.

The letter also highlights the potential for market distortions if the MRV is not applied uniformly. The airlines note that EU carriers already report carbon emissions for extra-EEA routes, and there is no clear reason why the same principle should not apply to non-CO2 emissions reporting. They argue that the MRV is the principal tool at the EU’s disposal to advance the science of non-CO2 effects and that it must gather a representative and non-discriminatory dataset of all types of flights, including short and long-haul, intra- and extra-EU, day and night routes.

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