The European Low fares Airlines Association has expressed concern over the adoption by the Environmental Committee
of the European parliament of the Lucas Report on reducing the climate
change impact of aviation.The most worrying aspect of the Report is
that its stated objective is to limit the demand for air services.  This
is not the purpose of the Emissions Trading Scheme (ETS).  Rather ETS
was designed to ensure that producers are incentivised to operate
efficiently and limit the amount of CO2 emissions from their activities
whilst contributing to the overall goal of the scheme ie to reduce EU
CO2 emissions.

Speaking on the publication of the Report by the Committee on the
Environment, Public Health and Food Safety of the European Parliament on
the Commission communication “Reducing the Climate Change Impact of
Aviation”, ELFAA’s new Secretary General, John Hanlon, said:

“ELFAA has consistently called for the debate on the inclusion of
aviation in ETS to be factually based and balanced.  In order to dispel
some of the serious inaccuracies that have characterized the debate on
the impact of aviation on CO2 emissions, and to highlight the huge
benefits that aviation brings to the European economy, ELFAA
commissioned a detailed report by London based Frontier Economics.
Other work in this area has been done by the Netherlands Environment
Assessment Agency.  he basic fact is that aviation contributes less than
3% of total EU CO2 emissions (i.e., when the new EU accession states
are included), compared to 34% by the power generation industry and 20%
by road transport. Aviation’s share of total EU emissions of CO2 is
forecast to only grow to 5% by 2030.

In terms of the benefits brought to the economy from the aviation
sector, low fares airlines and aviation in general bring much higher
economic value per tonne of CO2 emitted than other sectors (see below
chart). Aviation currently contributes over Euros 220 billion per
annum.and accounts for over 3 million direct jobs
This does not include the indirect benefits to business, tourism and the
development of the regions.

That is not to say that the airline industry in general and the low
fares sector in particular do not take CO2 emissions seriously.  Soaring
kerosene prices already make it vital for airlines to reduce fuel burn
to the minimum.  ELFAA airlines are therefore, of necessity, focused on
highest possible fuel efficiency and have invested billions of euro in
fleet replacement programmes in order to ensure that they have the most
fuel efficient aircraft.  They have also adopted efficient operational
measures to further limit fuel burn and therefore CO2 emissions.  LFAs
also operate in the main to secondary airports, easing congestion and
concentration of pollution at congested hubs.  They also provide direct
services to the regions, eliminating the need for multi-sector
itineraries and saving many millions of miles in car journeys to distant
hub airports.

The low fares airlines have been calling for a proper cost benefit
analysis to be carried out (which is required under the Commission’s
Better Regulation Initiative) before proceeding further with plans to
include aviation in the ETS.  ELFAA believes there is an urgent need
to revisit all of the possible alternatives for addressing aviation
emissions, including focusing on the inefficient Air Traffic Management
(ATM) system in Europe (which currently accounts for 12% of needless
emissions).  If this demonstrates that the ETS is the most cost
effective means of addressing aviation emissions, then the system must
be designed in a manner that encourages airlines to operate efficiently
and penalizes those airlines that are operating inefficiently and are
therefore contributing to the problem.

We sincerely hope that this Report does not become the basis for
proceeding with the process of determining whether aviation is added to
the ETS as its conclusions are highly suspect and are not based on the
facts.  Including aviation in the ETS without considering the full
picture could be highly damaging to the competitiveness of the industry
and will have wider repercussions for the wider European economy.”
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