Letter

Non-CO2 emissions: NGOs, airlines and aviation industry actors call upon the European Commission to monitor non-CO2 emissions on all flights

May 6, 2024

Limiting the scope of the non-CO2 monitoring tool risk limiting both our understanding and ability to mitigate the impact of non-CO2 effects of aviation.

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Non-CO2 effects from aviation, including nitrous oxides emissions and contrail formation, are known to have an impact on the climate. While our knowledge of these effects today may not be as extensive as that of CO2, scientific consensus, gathered by EASA in its 2020 report, highlights that their warming effects could have a similar impact as CO2, or even larger.

Acknowledging their environmental impact, the groundbreaking EU ETS agreement adopted in 2022 has paved the way for addressing non-CO2 effects by requiring the development of a Monitoring, Reporting and Verification (MRV) framework. This represents a historic first step to understand and act as appropriate on non-CO2 effects, as it can help boost research and inform policymakers and the aviation industry on the best set of policies and incentives for their effective mitigation.

A key feature of the MRV framework is the full geographic scope of the reporting. It includes all flights entering or leaving the European Economic Area (EEA). This is consistent with the general scope of the EU ETS Directive for other transport modes and their non-CO2 emissions. Shipping companies are required as of 2024 to monitor maritime non-CO2 emissions (nitrous oxide (N2O) and methane (CH4)) for voyages to, from, and within the EU.

It is critical that the full geographic scope is retained, as it is the only scientifically sound basis to understand the impact of aircraft types and geographies, and allow a better understanding of the impacts of long-haul flights which research shows to cause more warming and present larger mitigation opportunities. It is vital that activity in areas such as the North-Atlantic region, with a high concentration of contrail formations, are monitored and understood.

That’s why a coalition of NGOs, airlines and other aviation industry actors are coming together to call upon the European Commission to maintain the full scope of the non-CO2 MRV.

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