Notification under the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA)

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

Please see the attached feedback from Airlines for America (A4A). Note that our comment letter addresses the updated provisions for aviation under the EU Emissions Trading System as well as ReFuelEU Aviation and the amendment of the Renewable Energy Directive (i.e., RED III).

Ryanair Holdings plc, Europe’s largest airline group, carried 149m guests p.a. (pre Covid-19) on more than 2,500 daily flights from over 80 bases, connecting over 225 destinations in 37 countries and contributing to the building of a united Europe. Ryanair is Europe’s greenest and cleanest airline group.

The Commission is proposing to reform the EU ETS rules for aviation to try and address some unfair privileges the sector was benefiting from and start applying a more effective price on aviation emissions. But it unfortunately continues to implement Corsia, ICAO’s carbon offsetting scheme despite its confirmed lack of economic and environmental integrity.

The International Council on Clean Transportation (ICCT) welcomes the opportunity to comment on the Proposal to revise the EU Emissions Trading Scheme (ETS) treatment of aviation emissions. The ICCT is an independent non-profit organization founded to provide first-rate, unbiased technical and scientific analysis to environmental regulators.

Hydrogen Europe stands for reforming carbon markets to enable a liquid, sustainable and affordable hydrogen market. A revised, more ambitious EU ETS will be an essential for deep decarbonisation. In this context, carbon content of energy carriers should become the “new currency” of the EU economy, as well as the basis for a stable economic recovery.

AeroSpace and Defence Industries Association of Europe (ASD) thanks the European Commission for this opportunity to comment on their proposals to amend the EU ETS with regards to aviation and the overall system. ASD is committed to the ultimate objective to reach a net-zero emissions aviation ecosystem in Europe by 2050, and to strongly contribute to the EU’s 2030 ambition.

On the topic of the implementation of the CORSIA regulations, we grant a full approval for the obligation to adapt the current European regulations and the provisions of individual Member States. An important element in the adaptation of the CORSIA system is the proper division of flights between two separately operating systems with the aim of reducing CO2 emissions in aviation.

Japan would first like to take this feedback opportunity to congratulate the European Commission on the broad scope of its Fit for 55 package and its high level of climate ambition. Taking this opportunity, Japan would like to share our views as follows.

Aena advocate for the EU Emissions Trading System as an effective carbon pricing mechanism, including for aviation. We support the proposed progressive tightening of the overall ETS emissions cap based on an annual linear reduction factor of 4.2%, as it is in line with the guidance defined by the Science-Based Target initiative to implement the IPCC 1.5°C scenario.

Feedback German Aviation Association Directive on the revision of the EU ETS in aviation The European Emission Trading System (ETS) is a market-based system to reliably reduce CO2 emissions. The aviation sector is included in the ETS since 2012. The BDL assesses ETS as a very effective climate protection instrument and therefore we are highly welcoming the revision of EU ETS.

The European Business Aviation Association (EBAA) welcomes the opportunity to be able to participate and comment on the Revision of the EU Emissions Trading System Directive 2003/87/EC concerning aviation (through amendment in 2008 for aviation) and be able to provide input to this process. Please see the EBAA response in the attached document.

The European Regions Airline Association (ERA) welcomes the opportunity to provide input to the European Commission’s revision of the EU Emission Trading System Directive concerning aviation. ERA is the trade association representing more than 60 airlines and 150 associate members, including manufacturers, airports, suppliers and aviation service providers, across the entire spectrum of the aviation industry.

We are grateful for the excellent working relationship we enjoy with our European Commission and European Union Member States counterparts at the International Civil Aviation Organization (ICAO), and so it is with great interest that we are following the process to revise the EU Emission Trading System Directive 2003/87/EC concerning aviation.

3892 pre changes Environmental Defense Fund welcomes the opportunity to comment on the Inception Impact Assessment on a revision of the EU ETS for aviation. When evaluating policy options for CORSIA and EU ETS, the Commission should assess their consistency with the Paris Agreement obligation to pursue further climate ambition as well as the Chicago Convention, as the EU noted in the context of ICAO Assembly…

EU aviation emissions have more than doubled since 1990. If the European Green Deal is to radically reduce the EU’s climate impact, every sector has to contribute to the fight against the climate crisis. One of the most effective ways to tackle the increasing emissions from European aviation is by revising the Emissions Trading System (ETS).

Citizens’ Climate Europe (CCE) appreciates the EU’s high ambitions to tackle climate change. All sectors will have to contribute to achieve these goals, including aviation. Such efforts must begin immediately and increase steadily. As a global leader on climate change the EU must avoid policies that could limit its ambition.

ACI EUROPE and its members have been engaged in climate action for many years and in July 2019 commited to reach Net Zero carbon emissions from operations under airports' control by 2050. We welcome the opportunity to provide feedback on the European Commission Inception Impact Assessment addressing the future of the EU ETS and its interaction with CORSIA. Our main comments are summarised below.

DVF reaffirms the target of zero emission mobility by 2050. The task of ETS and CORSIA is to give CO2 a price tag, to increase the incentives for low-emission investments and operations, and to offset remaining aviation emissions with effective measures in other sectors. Aviation is a global mode of transport.

With the publication of the European Green Deal in December 2019, the European Commission announced the revision of the EU Emission Trading System Directive 2003/87/EC also concerning aviation, with a proposal to be adopted by June 2021. This position paper constitutes Air France-KLM’s initial views towards the announced revision.

In the Inception Impact Assessment it says: The failure to put a price on carbon/climate externalities is equivalent to subsidising polluting activities. This is at the core of the challenge. The Swedish 2030-secretariat was formed to be a collected voice, a coalition of the willing - of business and business groups wanting to see a fast decarbonization of the transport sector.

Option 1 (“full legal scope for the EU ETS”) is the best of the proposed option. CORSIA does not reduce CO2 emissions at all but only future climate compensation. The damage is already distorted, the concentration of CO2 in the atmosphere has increased with all the disastrous consequences it will entail. Climate compensation does not prevent these consequences.

Filed in Swedish · English published by the European Commission

Deutsche Post DHL Group provides an international service portfolio consisting of mail and parcel delivery, express delivery, freight transportation, supply chain management and e-commerce solutions. With approximately 550,000 employees in over 220 countries and territories worldwide, we are one of the world’s largest employers in the transportation and logistics sector.

ECA is the representative body of European pilot associations, representing 40.000 pilots from across Europe. More info about ECA at www.eurocockpit.be. ECA supports a gradual reduction of the ETS allowances allocated for free to airlines and strongly urges that the additional revenues generated be earmarked to contribute to actively promote the development of SAF, and more specifically the 'electro-fuels' which are…

AeroSpace and Defence Industries Association of Europe (ASD) thanks the European Commission for this opportunity to comment on its plans for the revision of the EU Emission Trading System Directive 2003/87/EC concerning aviation.

MOL Group’s answers to the public consultation MOL Group welcomes the European Green Deal and its direction to tackle climate change and make Europe the first climate neutral continent and appreciates the possibility to contribute to the IIA of ETS revision concerning aviation.

Sandbag welcomes the opportunity to give feedback on the Inception Impact Assessment on updating the EU ETS rules for aviation. In the context of the European Green Deal and the enhanced ambition for 2030, changes to the EU ETS for aviation should not result in a step backwards in terms of tackling CO2 emissions, but a step forward.

We are convinced that the revised EU Emission Trading System (EU ETS) Directive 2003/87/EC will be a cornerstone of the environmental policy for the aviation industry that will shape the environmental legislation for European aviation for years to come. One of the key challenges for the EU will be to create a regulatory foundation that allows for the coexistence of EU ETS and ICAO’s CO2 offsetting program CORSIA.

The German aviation industry is committed to the EU climate goal of greenhouse gas neutrality by 2050. We welcome the EU's support for the UN aviation organization ICAO in designing the climate protection and CO2 pricing instrument CORSIA. The ICAO has thus fulfilled its responsibility to include CO2 pricing in the emissions of international flights (i.e. including flights between two EEA member states).

Regarding the increasing of the percentage of auction, any increase should be in accordance with the European Green Deal and EU’s economy-wide greenhouse gas emission reduction target and commitments under the Paris Agreement.

The ICCT applauds the European Commission’s intention to secure the aviation sector’s contribution to EU climate goals. While other sectors have made significant progress in deploying renewable energy and improved efficiency to curb or even reduce their emissions, emissions from international flights in Europe have increased by 141% since 1990.

ince 2013, European aviation CO2 emissions have increased 27.6% compared to a 19.7% decrease for other sectors in the ETS. However, aviation has so far escaped its responsibility to cut emissions compared to other sectors. It will be increasingly socially and politically untenable for the aviation sector to continue to grow despite measures in place to decarbonise other sectors.

Emirates Airline appreciates the opportunity to provide feedback on the Inception Impact Assessment on the revision of the EU ETS Directive 2003/87/EC concerning aviation. As a global airline providing connectivity between European cities and destinations worldwide, Emirates has been a participant in the EU ETS since coverage was extended to aviation.

The Coordination Office of the Austrian Episcopal Conference for International Development and Mission (KOO) welcomes the invitation to comment on this inception impact assessment. As we were following the development of CORSIA throughout the last years and pointing out the weak points of the proposed system, we welcome the broad scope of the options presented in this impact assessment.

The International Air Transport Association (IATA) welcomes the opportunity to comment on the inception impact assessment to the revision of the EU Emission Trading System Directive 2003/87/EC concerning aviation. IATA is the global trade association of the world’s airlines representing more than 290 airlines.

FuelsEurope’s response to the consultation on the inception impact assessment on the revision of the EU Emission Trading Directive (ETS) 2003/87/EC concerning aviation. FuelsEurope supports the Green Deal’s ambition for climate neutrality in 2050 and will work with the EU institutions, Member States, and stakeholders, to help create the essential enabling policy framework.

While every other sector’s climate emissions have decreased since 1990, on average, aviation emissions have more than doubled. If the European Green Deal is to radically reduce the EU’s climate impact, it has to reshape European aviation by using all necessary carbon pricing tools at its disposal, including revising the Emission Trading System (ETS).

German industry is committed to the objectives of the Paris Climate Protection Agreement. The extremely ambitious climate protection goals of the EU for the transport sector also apply to air transport and must be reconciled with economic efficiency, international competitiveness, social concerns, and international principles.

The aviation sector continues to benefit from important privileges in the EU, despite its significant climate impacts. EU policies should be revised to ensure that the aviation sector pays a fair price on its GHG emissions, thereby enforcing the polluter pays principle.

IETA welcomes the opportunity to provide initial feedback on this important topic. Like many organisations, IETA is keen to take the time necessary to study this complex issue in full. Here we pose preliminary comments that we believe should be considered when coming to a decision about Aviation. A more formal position will be made clear in the full public consultation.

The aviation sector’s emissions have been growing much faster than other sectors around the world. At the same time the sector continues benefitting from numerous privileges in the EU, ranging from free allocation of allowances under the EU ETS, exemption from fuel taxes, exemption from VAT on international flights, state aid (e.g.

Railways provide clean mobility, with a very low carbon footprint compared to aviation. They are ready to help making European transport greener with a modal shift to rail. To support this shift, travel prices must reflect travel-related externalities, such as climate impacts, so that trains are enabled to compete with planes for customers also on prices. The EU ETS can support the shift to low-carbon mobility.

As also indicated in the document, the first thing that needs to be established is to which extent CORSIA, in its current shape, will contribute to the goals of the Paris agreement. It needs to be seriously considered whether CORSIA is a climate policy targeted to solve climate change, or whether it is an attempt to block any effective climate policy for the foreseeable future.

The United States appreciates the opportunity to provide comment as you gather information assessing the potential impacts of revisions of the European Union (EU) Emissions Trading System (ETS) Directive 2003/87/EC concerning aviation.

The full internalisation of the environmental costs is required to give consumers a price signal to incentivise the purchase of products with the lower carbon footprint (cheaper) and reduce GHG emissions efficiently. To this end, it is also important that emitters receive correct price signals to reduce emissions and undertake effective measures to reduce emissions.