Europaudvalget 2020-21
EUU Alm.del Bilag 263
Offentligt
2325812_0001.png
EU emissions trading system - updated rules for aviation
Denmark’s response to the public consultation
Center
Centre for Global Climate Ac-
tion
Team
Climate Neutral EU
Date
12 December 2020
Case No
2021 - 113
Denmark welcomes the Commission’s intention of presenting a legislative proposal
to implement the carbon offsetting and reduction scheme for international aviation
(CORSIA) in a way that is consistent with the EU’s 2030 climate objectives, as well
as the intention to present a proposal to increase the share of allowances auc-
tioned under the system for aircraft operators to further contribute to reducing
greenhouse gas emissions.
Greenhouse gas emissions from the aviation sector have more than doubled over
the past three decades and is projected to increase further in the future. One of the
many reasons behind this is the fact that the growth in volume in the aviation sector
has outpaced the initiatives taken to reduce emissions.
Today, aviation accounts for
more than 3 percent of the EU’s total greenhouse gas
emissions and more than 13 percent of the CO2 transport emissions. Aviation is in
addition one of the fastest-growing sources of greenhouse gas emissions. In order
to address this issue, swift and targeted action is needed to reverse the trend of in-
creasing emissions from the aviation sector.
The European Union Aviation Safety Agency presented in September 2020 its re-
port entitled “Updated
analysis of the non-CO2 climate impacts of aviation and po-
tential policy measures pursuant to EU Emissions Trading System Directive Article
30(4)”.
The report
emphasized a range of findings including that aviation emissions
are currently warming the climate at approximately three times the rate of that as-
sociated with aviation CO2 emissions alone due to the impact of e.g. soot, particu-
lar emissions and condensation trails. When considering long-term regulation of
the emissions from the aviation sector, all relevant climate effects should be taken
into account.
In addition, it is very important to underline, that the aviation sector is still in an un-
precedented situation due to the restrictions taken in response to the COVID-19
pandemic. This means that all regulatory steps addressing the fundamental operat-
ing circumstances of the aviation sector has to consider the unique situation and
be adopted with careful consideration.
/ MIMAN
Side 1/3
 EUU, Alm.del - 2020-21 - Bilag 263: Notat samt høringssvar vedr. implementering af CORSIA og udfasning af gratiskvoter til luftfarten
2325812_0002.png
Increase of the share of allowances auctioned under the EU ETS
The EU ETS has rightly demonstrated itself as a flagship EU climate policy. Nota-
bly after the 2018 revision of the EU ETS directive, the system has succeeded in
establishing an effective EU-wide carbon price signal that has provided incentives
to reduce emissions cost-effectively across Member States. An effective carbon
price through the EU ETS is the most cost-effective instrument to deliver on the
EU’s climate targets as well as to incentivise market-driven
deployment of low-car-
bon technologies and phase-out of fossil fuels across sectors
–
including within the
aviation sector.
In order to create an effective EU-wide, uniform carbon price signal, it is of great
importance that differences between and within sectors are reduced. However as
the situation stands now, aviation transportation is not sufficiently priced compared
to other means of transportation. This fact was recently highlighted in the European
Court of Auditors' Special Report No 18/2020 entitled “The
EU’s Emissions Trading
System: free allocation of allowances needed better targeting”.
The Special Report
highlighted in particular that the allocation of free allowances for the aviation sector
have tended to favour air travel over other modes of transportation within the EU
such as rail travel.
In this light, the Commission is encouraged to analyse the level of allocation of free
allowances to secure climate action across all sectors, while taking fully into ac-
count the international competitiveness of sectors in risk of carbon leakage.
Therefore, Denmark welcomes the Commission’s intention to present
options for
adjusting the share of allowances auctioned under the system for aircraft operators
with a view to ensure further reductions of greenhouse gas emissions and a level
playing field with other modes of transport.
CORSIA implementation
By its very nature, aviation presents cross-border challenges best responded to by
cross-border
solutions. As such, the EU’s Emissions Trading System has since
2012 covered certain emissions from the aviation sector. However, as aviation
emissions are not confined to neither the EU nor the EEA, measures to address
aviation emissions on a broader scale are quintessential.
The carbon offsetting and reduction scheme for international aviation (CORSIA) as
negotiated in the International Civil Aviation Organisation (ICAO) is an important
step in order to address global emissions.
In order to support the momentum in the ICAO, extra-EEA flights have been tem-
porarily excluded from the EU ETS. As the temporary geographical scope deroga-
tion is due to expire by the end of 2023, it is important to address the co-existence
of the EU ETS and the CORSIA when it comes to regulating emissions from the
aviation sector.
Page 2/3
 EUU, Alm.del - 2020-21 - Bilag 263: Notat samt høringssvar vedr. implementering af CORSIA og udfasning af gratiskvoter til luftfarten
2325812_0003.png
As CORSIA by design is capable of complementing domestic and regional action
such as the EU ETS, any implementation of CORSIA should have as one of its
goals to uphold an effective carbon price. The implementation of CORSIA should
as such aim to complement the existing EU ETS in a cost-effective manner.
Taking into account the current level of ambition of CORSIA, the Danish govern-
ment still sees a very relevant and prominent role for the EU ETS regarding further
reductions of greenhouse gas emissions from the aviation sector. The Danish gov-
ernment supported originally the temporary exclusion of extra-EAS flights, but pre-
fers that any future solution would deliver a similar potential for emissions reduc-
tions as with the EU ETS.
Any action taken to implement CORSIA should have as its main focus to increase
the climate and environmental ambitions for the greenhouse gas reductions in the
aviation sector. It is paramount that the aviation sector contributes to the decarbon-
isation of the transport sector in particular as well as the EU climate goals in gen-
eral. Therefore, any option taken regarding the coverage of the EU ETS and the
CORSIA respectively must take into account the Paris agreement’s principle of “no
backsliding”.
A key aspect to keep in mind when regulating aviation transport is the question of
carbon leakage. One of the challenges to the transition of the aviation sector is to
ensure that ambitious European efforts will not only result in the emissions being
moved to non-EU countries. In that regard, CORSIA will play a crucial part over the
coming years. Especially the implementation during the pilot phase will prove to be
instrumental in order to achieve tangible results both within and beyond the EU.
Finally, it is of great importance that any course taken in terms of the coordination
of the EU ETS and CORSIA with regards to aviation emissions are coordinated in
such a way, that no regulatory gaps will occur between the scope of the two sys-
tems. Furthermore, any regulatory action taken should take into account the ambi-
tion to minimise the administrative burdens that might arise from having co-existing
systems.
Page 3/3