Opinion of the European Economic and Social Committee on the Communication from the Commission to the Council, the European Parliament, the European Economic and Social Committee and the Committee of the Regions — Reducing the Climate Change Impact of Aviation  COM(2005) 459 final
Date: 2006-04-21
Institutions: European Economic and Social Committee
Subjects: ESC opinion, EU programme, air transport, climate change, environmental impact, reduction of gas emissions, tradeable emission permit

8.8.2006

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Official Journal of the European Union

C 185/97

Opinion of the European Economic and Social Committee on the Communication from the
Commission to the Council,
the European Economic and Social
Committee and the Committee of the Regions — Reducing the Climate Change Impact of Aviation

the European Parliament,

COM(2005) 459 final

(2006/C 185/17)

On 27 September 2005 the European Commission decided to consult the European Economic and Social
Committee, under Article 262 of the Treaty establishing the European Community, on the abovementioned
proposal.

The Section for Agriculture, Rural Development and the Environment, which was responsible for preparing
the Committee's work on the subject, adopted its opinion on 21 March 2006. The rapporteur was
Mr Simons.

At its 426th plenary session, held on 20 and 21 April 2006 (meeting of 21 April), the European Economic
and Social Committee adopted the following opinion nem. con. with 55 votes in favour and one absten-
tion.

A. Conclusions

Like the Commission, the EESC is of the opinion that
A.1
additional (policy) measures are needed to control the impact
of aviation on climate change. The increase in aviation's contri-
bution to greenhouse gas emissions will be approximately 50 %
of the annual percentage increase in aviation, even if all the
ambitious R&D goals are achieved over the coming decades.
The budgets reserved for this in the 7th Framework Programme
will have to be spent in a targeted and effective way.

To limit

A.2
the European
the impact on the climate,
Commission has set a policy goal for the reduction of CO2 and
NOx emissions in the EU, beginning with the period 2008-
2012. Taking account of international treaties, agreements and
ongoing studies, the EESC is of the opinion that potential
measures for aviation should initially apply only to CO2 emis-
sions from intra-EU air traffic in order to minimise potentially
long implementation delays.

It will be necessary to work through the International
A.3
Civil Aviation Organization (ICAO)
in order to ensure the
worldwide application of an Emissions Trading Scheme (ETS);
as a practical first step, an intra-EU ETS could be a very feasible
option, if this proves appropriate in the course of the negotia-
tions.

A.4
From the earliest date possible, all intra-EU air traffic
should be included in an open (EU) Emissions Trading Scheme,
with a realistic baseline scenario, in order to reflect its (annually
increasing) CO2 contribution to climate impact. There should
be allocations at EU level and additional contribution/reduction
targets should apply directly to the airlines as the trading
parties; it must remain possible for new operators to enter the

market, without competitive disadvantage. For other impacts,
use should be made of more appropriate local
instruments,
such as an NOx levy or operational measures.

A.5
Investment in research into the climate change effects of
aviation's non-CO2 emissions and technological developments
to secure cleaner air transport should be a key priority for the
Community and industry, with particular
emphasis on
preventing adverse trade-offs between local noise, local emis-
sions and global emissions of aircraft.

Given its emission reduction potential,

improved air
A.6
traffic management should also be a priority, using the Single
Sky Initiative and the SESAR programme.

A.7
Non-discriminatory measures to improve the competi-
tive position of surface travel modes should be further explored
in order to offer more attractive alternatives for passenger and
cargo transportation within the Community.

B. Reasons

B.1 While the contribution of aviation emissions to climate
change is relatively small (around 3 %), it is forecast to grow
due to increasing demand,
the absence of alternative fuel
sources and the relative maturity of current aircraft technology.
Even when all ambitious EU R&D goals are realised and imple-
mented in the next decades, the increase in CO2 output of avia-
tion will be 2 to 2.5 % per year, or roughly half of its annual
growth (forecasted to be 4 to 5 % per year).

B.2
An ETS offers the most cost effective solution to limiting
the climate change effect while facilitating the sustainable
development of aviation.

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The problem is global

B.3
in nature and thus demands a
global solution. In the interim, if appropriate, the establishment
of an intra-EU scheme represents a first step which can be used
as a blueprint for global application through ICAO.

B.4
For this reason, an EU scheme should be as unconten-
tious as possible, being initially limited to CO2 without the
application of multipliers. The effects of non-CO2 emissions
(which have no Kyoto Protocol equivalent values) are scientifi-
cally less well understood although there are indications that
certain non-CO2 emissions could have effects in some cases.
Pending further research, such effects should be the subject of
standardised EU-wide local instruments where necessary, such
as a NOx levy.

B.5 Where they exist, high speed trains have been shown to
represent a valuable alternative to passenger air travel on
certain European routes, which see enormous volumes of
traffic having flight times of one hour or less. Studies should be
carried out to evaluate the potential for their expansion and the
possibility of providing such services for freight transportation,
taking care to prevent distortion of competition by national or
EU subsidising. However, trains should not be expected to ever
become a full equivalent alternative to more than a part of
intra-EU air traffic.

1. Introduction

Air transport has become an integral part of society in
1.1
the 21st century, enabling both passengers and freight to travel
large distances at an unprecedented speed and providing signifi-
cant economic benefits to regional and national economies.
However, aviation also contributes to climate change. Although
aircraft fuel efficiency has increased by more than 70 % over
the last 40 years, the total amount of fuel burned has increased
by over 400 % in that time due to even higher growth in air
traffic which in turn is the result of
travel requirements/
demand.

As a result, the impact of aviation on the climate is on
1.2
the rise and is the fastest growing single source of greenhouse
gases in the area of transport: whilst the EU's total emissions
controlled under
fell by 5.5 % (-287
MtCO2e) from 1990 to 2003,
its greenhouse gas emissions
from international aviation increased by 73 % (+47 MtCO2e),
corresponding to an annual growth of 4.3 % per year. The
growth in air traffic in the EU since 1990 has, however, been
much faster. This shows that the aviation industry is attempting

the Kyoto Protocol

to tackle the environmental
technology.

impact at source using efficient

1.3
In this connection, tackling the problem at source is an
effective (initial) measure. In the short, medium and long term,
the remaining contribution cannot be compensated for by the
aviation industry itself, except by an enforced but unrealistic
slowdown in growth of air traffic.

1.4
Although aviation's share of overall greenhouse gas
(about 3 % (1)),
emissions is still modest
the rapid growth
the growth
undermines progress made in other sectors.
continues as up to now, by 2012 emissions from international
flights from EU airports will have increased by 150 % since
1990. This growth in the EU's international aviation emissions
would offset more than a quarter of the reductions required by
the Community's target under the Kyoto Protocol.

If

1.5
In the longer run, aviation emissions will become a
more significant contributor if current trends continue, with
the proportion of total EU CO2 emissions arising from aviation
increasing from 3 % in 2005 to approximately 5 % in 2030
due to a doubling of air traffic. An ETS would reduce demand
to some extent but, to compensate for the expected growth in
air traffic, the sector would have to acquire credits from other
credit holders to ensure that growth did not undermine the
Community's Kyoto targets as mentioned above.

2. Summary of the Commission communication

2.1
On 27 September 2005, the Commission published its
Communication on existing and possible additional policies
which would attempt to stop this trend either indirectly or
directly.

Existing policies, for example the EU's Sixth Framework
2.2
Programme for Research, focus, inter alia, on public awareness,
encouraging the use of alternative modes of transport and
carrying out research into cleaner air transport. The forth-
coming Seventh Framework Programme will focus even more
closely on the climate change impact.

2.3
Planned policies such as improved air traffic control
management (under the Single European Sky programme) will
attempt to achieve a medium-term reduction of approximately
10 % by improvements in efficiency in the use of European air
space.

2.4
Policies previously discussed such as the possible intro-
duction of an energy tax for air transport (fuel), or a tax on
tickets (in the EU), could possibly bring the impact of air trans-
port on climate change only partially under control.

(1) Aviation is one of the cleanest and most economical forms of trans-
port. The transport sector as a whole accounts for about 22 % of all
global CO2 emissions from fossil fuel use. Results from the Intergo-
vernmental Panel on Climate Change (IPCC) demonstrate that,
within the transport sector, the largest contributor to greenhouse
gas emissions is road transport (75 % of total transport CO2 emis-
sions). The share of aviation is only 12 %. Consequently, aviation is
responsible for only about 2 %-3 % of total global CO2 emissions
(12 % of 22 %).

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2.5
The Commission therefore also recommends that the
impact of air transport on climate change be included in the
European Emissions Trading Scheme (EU ETS), to complement
existing policies. In the Commission's view, this fits in well
with the policy of the International Civil Aviation Organisation
(ICAO), which does not explicitly endorse energy taxes, but
rather the concept of international open trading in emission
rights to be implemented through voluntary emissions trading
or the incorporation of international aviation into the coun-
tries' existing schemes.

The Commission identifies the following key design
2.6
parameters in its Communication and gives them its provi-
sional approval:

— trading party: aircraft operators;

— type of emissions: CO2 and non-CO2 effects where possible;

— scope: all departing flights (within and from the EU);

— allocation method: harmonised at EU level.

A working group of experts from Member States and
2.7
the key stakeholders:
industry, consumer and environmental
organisations, has the task of advising EU officials by May
2006 on the way to incorporate aviation into the ETS system,
cf. the terms of reference in the annex to the Communication.
Legislative proposals are expected in late 2006.

3. General comments

3.1
The worldwide impact on climate as a consequence of
(man-made) emissions of greenhouse gases is by now recog-
nised by nearly every country in the world. However, there is
still a considerable difference of opinion about the best way of
tackling the problem. Countries such as the United States and
China, which are responsible for a substantial proportion of
worldwide greenhouse gas emissions, have opted for innovative
at-source measures as the spearhead of their approach and
have recently concluded international agreements on the
subject.

3.2
The Kyoto Protocol, signed in 1997 and ratified by
Russia, Canada and other countries, as well as the EU, aims for
an EU-average reduction of 8 % in greenhouse gases over the
period 2008-2012 compared with 1990 levels, with different
percentage reductions per Member State. Part of these reduc-
tion commitments can be achieved by (more cost-efficient)
measures abroad.

3.3
The European Climate Change Programme (ECCP) was
set up in the EU in 2000, under which the new EU Emissions
Trading Scheme (ETS) for CO2 was developed, which entered
into force for all fixed sources of emissions on 1 January 2005.
Transport is not (yet)
included in the EU ETS for the first
trading period up to the end of 2007, but may be for the
second period from 2008 to 2012. Moreover, international air

transport is one of the areas not included in the current Kyoto
Treaty and objectives.

3.4
In order to secure the global application of the aviation
rules, the way forward is through initiatives and negotiations
under ICAO auspices.

3.5
Commercial aircraft operate at cruise altitudes of 8 to
13 km, where they release gases and particulates which alter
the atmospheric composition and contribute to climate change.

Carbon dioxide (CO2) is the most important greenhouse gas
because of the large quantities released and its long residence
time in the atmosphere. Increasing concentrations have a well-
known and direct effect which warm the earth's surface.

Nitrogen oxides (NOx) have two indirect effects on the
climate. Nitrogen oxides produce ozone under the influence of
sunlight, but they also reduce the ambient atmospheric concen-
tration of methane. Both ozone and methane are strong green-
house gases. Overall, however, the ozone effect predominates,
thus warming the earth.

Water vapour (H2O) released by aircraft has a direct green-
house gas effect, but as it is quickly removed by precipitation
the effect is small. However, water vapour emitted at high alti-
tude often triggers the formation of condensation trails, which
tend to warm the earth's surface. Moreover, such ‘contrails’
may develop into cirrus clouds (clouds of ice crystals). These
are also suspected of having a significant warming effect,
although this is far from certain.

Sulphate and soot particles have a much smaller direct effect
compared with other aircraft emissions. Soot absorbs heat and
thus has a warming effect; sulphate particles reflect radiation
and have a slight cooling effect. In addition, they can influence
the formation and properties of clouds.

3.6
In 1999 the Intergovernmental Panel on Climate Change
(IPCC) estimated that the total climate impact of aviation was
potentially some 2 to 4 times greater than the effect of its CO2
emissions alone; latest insights indicate that this effect is most
likely to be in the factor 2 region, and updated IPCC conclu-
sions are expected in the near term.

3.7
As fuel used in international aviation is exempt by
treaty from taxation, this places aviation in a privileged posi-
tion in comparison with other transport modes. It is true that,
for example, aircraft operators pay their own infrastructure
costs in terms of en-route and airport charges (the latter
increasingly including environmental elements); environmental
charges in the form of passenger duties; and enjoy subsidies
only in the case of routes to which Public Service Obligations
apply; but in this respect other forms of transportation also
bear equivalent charges.

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4. Specific comments

— not a new policy instrument; first phase already opera-

tional.

4.1
An intra-EU ETS — that may, if appropriate, be brought
into the ICAO negotiations as a first practical step — would be
an addition to existing policy instruments, such as increasing
to sustainable mobility,
awareness with regard
public
promoting alternative means of
transport and encouraging
research into cleaner air transport.

Possible additional

4.2
aviation:

instruments to limit the impact of

For the EESC, the most probable shape of an initial EU

4.7
ETS for air transport is:

— CO2 only if early inclusion of aviation is of key importance:

— The only substance with good scientific evidence

regarding its effects

— Other options are either not (yet) practicable,

lead to
delay, or still lack sufficient scientific evidence (covering
all non-CO2 impacts)

— taxation: kerosene duty (fixed percentage) or VAT on

tickets;

— Other environmentally harmful substances, such as NOx, by

means of more appropriate flanking instruments

— levies:

flat-rate or progressive
amount per passenger or aircraft;

(per kilometres

flown)

— Emission rights to be allocated at EU level:

— emissions trading: inclusion of EU aviation in the open EU

ETS.

4.3
The alternative, taxation (an EU duty on kerosene or
VAT on tickets), would, according to research conducted for
the Commission, have the greatest impact on the demand for
air transport (at least –7.5 % in 2010) and the least effect on
CO2 emissions (-0.9 to –1.5 %). There would be no incentive
for cleaner air transport.

4.4
Another alternative, a levy per passenger, would be
relatively easy to introduce, but there would be no incentive
whatsoever to reduce the greenhouse gas emissions per aircraft
movement, the policy goal. On the other hand, depending on
its level, this form of taxation could possibly have a major
impact on air transport demand and consequently on the
competitive position of the European (aviation) industry.

4.5
A more realistic option, certainly in the short term,
would be the introduction of a levy per aircraft, possibly as a
flanking policy for non-CO2 effects. These levies can act as a
stimulus for cleaner flying and they have a lesser impact on air
transport demand. A levy per aircraft could also be imposed on
carriers from outside the EU, provided that the revenues were
used to protect the environment.

— Bad experience with national allocation plans for fixed
sources when allocation is made at Member State level

— Aviation is pre-eminently a market with international

competition, preventing market disruption

— Emission rights to be granted to airlines

— ensuring the most effective and efficient

incentives

within the scheme

— Allocation method: non-discriminatory

— Grandfathering clause, benchmarking of performance or

auction

— Equal treatment with respect to other sectors in the

open EU ETS

— Care should be taken not to ‘punish’ already efficient

airlines and new entrants

— Exclusively for flights within the EU, not

(yet)

for all

departing/arriving flights:

— There is no ideal solution, the most pragmatic solution

is negotiations through the ICAO forum

However, the incorporation of air transport into an EU

4.6
ETS would have the following advantages:

— All airlines will be involved in this process, irrespective

of their country of origin.

— most cost-effective solution;

— environmental benefit, in terms of CO2 reduction, known in

advance;

4.8
A limited impact assessment was carried out by the
Commission at the time of the Communication and it was
noted that a more detailed impact assessment will accompany
any final proposal. The actual economic impact will depend,
inter alia, upon the likely trading price and allocation metho-
dology.

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4.9
A scheme covering intra-EU flights will affect EU opera-
tors in different ways. Firstly, differences in price elasticity will
result in significant variations in the effect on demand. In addi-
tion, the effect could depend on the percentage of an operator's
overall output represented by intra-EU services. Concerns have
been expressed that operators with small percentage coverage
could engage in cross subsidising between fare types or with
their longer haul services to the detriment of those carriers
with a large (or total) percentage of operations covered by the
scheme. These aspects require further consideration as part of
the impact assessment.

There are still many aspects of air transport in an EU
4.10
ETS which the EESC feels require study, for example in the
proposed and already active Working Group of Experts, before
a definitive position can be taken on methods and timing:

— lessons learned from the evaluation of emissions trading for
fixed sources, before aviation measures can be imple-
mented;

— problems arising from the introduction of aviation into the
EU ETS after the commencement of the second trading
period;

— future trading prices and their impact on the growth of

aviation;

— the overhead costs of emissions trading for aviation in rela-

tion to the planned targets;

— feasibility and manageability of emissions trading for avia-

tion;

— possibilities of aviation emissions trading into a worldwide
system via the ICAO and, if not feasible, the benefits and
losses of potentially purely regional implementation;

— further research into interference between slot allocation

and emissions trading in aviation;

— further

research into the effects of possible trade-offs
between CO2 and NOx emissions (a greenhouse gas, but
also a ‘local issue’ in the vicinity of airports in urban areas
in the EU).

Brussels, 21 April 2006.

The President

of the European Economic and Social Committee

Anne-Marie SIGMUND

Opinion of the European Economic and Social Committee on The institutional framework for
inland waterway transport in Europe

(2006/C 185/18)

On 14 July 2005, the European Economic and Social Committee, acting under Rule 29 (2) of its Rules of
Procedure, decided to draw up an opinion on: The institutional framework for inland waterway transport in
Europe

The Section for Transport, Energy, Infrastructure and Information Society, which was responsible for
preparing the Committee's work on the subject, adopted its opinion on 24 March 2006. The rapporteur
was Mr Simons.

At its 426th plenary session, held on 20 and 21 April 2006 (meeting of 21 April) the European Economic
and Social Committee adopted the following opinion by 57 votes with one abstention:

1. Recommendations

1.1
In its opinions of 16 January 2002 and 24 September
2003, the EESC called upon all stakeholders to continue to
work towards the goals of harmonising and integrating inland
waterway transport in Europe. Whilst they have lost none of
their validity, these opinions can be fleshed out in respect of
the issue of the institutional framework, in the light of develop-
ments which have occurred since its publication.

the CCNR and the Danube Commission, is a highly relevant
factor in this context. A permanent form of cooperation must
be set up and operate at a fundamental, structural level, as well
in the various inland
as at an early stage in the process,
waterway transport fields, and where appropriate involving the
social partners fully, so as to make policy-preparation as
robust, uniform and comprehensive as possible.

1.2
The further direct expansion and intensification of coop-
eration between the key players, i.e. the European Commission,

1.3
If we are ultimately to bring about a uniform system of
law governing pan-European inland waterway transport,
account must be taken of a number of aspects.