ELFAA, the European Low Fares Airlines Association, has published an official response to the
publication of the UK Parliament Environmental Audit Committee
report.It reads as follows:

ELFAA acknowledges the contribution of aviation to global emissions of
CO2, even though these represent only 3% of total EU emissions.
Notwithstanding this low proportion of total emissions, ELFAA member
airlines support the proposed inclusion of aviation in a
properly-designed EU Emissions Trading Scheme, capturing all flights
within, arriving in and departing from the EU, which ELFAA considers the
single most appropriate way of tackling the growth in emissions.

The allocation of a set target for aviation emissions would force
airlines to invest in the most technologically-advanced fleets, with
most improved fuel efficiency. 
ELFAA does not subscribe to the not-disinterested contention by some
parties that an equitable Emissions Trading Scheme for aviation with the
widest possible footprint is unachievable.
With airlines likely having to fund growth by purchasing CO2 allowances
from other sectors, better able to reduce their emissions in the short
and medium term, there would be a clear reduction in overall carbon
emissions.

The report’s focus on the claimed inequitability of the lack of tax on
aviation fuel is grossly misleading in that it fails to acknowledge
that, alone of all transport modes in Europe, aviation meets in full all
the costs of its infrastructure with none of the massive subsidies
enjoyed by road and rail. 

While ELFAA welcomes the proposed eco-labelling for aviation, the
various taxes proposed by the Committee - while they would increase the
cost of flights - would make no direct contribution to the environment.
The introduction of the existing UK Air Passenger Duty, which was
predicated on the environment, has resulted in no funds raised being
channelled towards the environment. All proceeds have, rather, accrued
directly to the Treasury. The sharp and continuing rise in fuel cost
already provides the most powerful incentive to aircraft operators to
optimise fuel burn. ELFAA members already operate the youngest aircraft
fleets which they operate with denser seating configurations and higher
Load Factors, further minimising fuel burn and resultant carbon
emissions per flown passenger mile.

There is no evidence to support the contention, implicit in the report,
that imposing swingeing taxes alters consumer demand for air travel
across the spectrum - witness the already high fuel surcharges levied by
many traditional airlines. What the proposed taxes would do, however, is
disproportionately affect the affordability of air travel for the budget
conscious, who have been the greatest beneficiaries of the far-sighted
liberalisation of air travel within the EU.

It is a pity that in its near single-minded focus on measures impacting
airlines and passengers, the report fails to address other factors with
significant scope to reduce emissions such as technological
breakthroughs by manufacturers and reform of the fragmented and
inefficient network of air traffic navigation service providers -
estimated to account for some 18% of unnecessary fuel burn by airlines.

The European Low Fares airlines have brought affordable air travel
within the grasp of millions of Europeans, who previously regarded it as
the preserve of the rich few. In so doing they have brought significant
benefits in socio-economic development to the regions of Europe.

The protection of the environment from the effects of aviation emissions
can be achieved through a properly-conceived Emissions Trading Scheme,
without the gross inequitabilities of the rough and ready taxation
measures proposed by the Committee. 
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