6.4.2022
EN
Official Journal of the European Union
C 152/153
1.4.
Financial intermediaries should be excluded from the EU ETS trading scheme, so that only installations emitting carbon dioxide in their production processes are allowed to trade emission allowances.
This is to eliminate any risk of speculation and is similar to the Chinese approach, which banned financial institutions from participating in their allowance trading system. 1.5.
The majority of extra-EEA traffic runs through central hubs either within or outside the EEA.
Currently, most passengers have a number of options for their extra-EEA flight through both internal and external hubs.
However, with the increased cost of the ETS, there is a significant risk that EEA operators will be undercut by cheaper operations based in hubs outside the EEA.
To counteract this, the allocation of free ETS allowances must be replaced by a targeted mechanism against competitive disadvantages in order to protect European airlines and European hubs. 1.6.
The EU must promote a more ambitious, uniform global regulation on carbon pricing, and must have a mandate to negotiate for this at global level.
In addition to its global mandate, we propose the application of one or both of these mechanisms in order to ensure fair and sustainable implementation of the ETS and support a broader application base in the short term: a) introducing a carbon border adjustment mechanism; b) replacing the free allocation system with targeted protection against unfair competition. 1.7.
The ETS should support a move towards more sustainable modes of transport, including within the aviation sector, and should therefore promote a reduction in the use of business aviation.
The ETS should encourage the use of sustainable mass transport and therefore force business jet users to pay higher charges. 1.8.
ETS revenues should be invested in development projects that will further reduce the environmental impact of aviation, by supporting a reduction in cost and greater uptake of SAFs.
It should also support the transition of airports, fuelers and ground handlers to new regulations being imposed on SAF usage in European airports through the ReFuelEU proposal.
Revenues must also support a just transition for workers in the aviation industry who have been negatively affected by climate change.
To implement this, an aviation social fund should be created that will allow for the training and transition of aviation workers.
Such a fund could be managed by the European Commission, with the support of both employers and trade unions. 1.9.
Through the ETS, the proposal should encourage operators to develop inter-modal transport networks in their major hubs in order to expand to a greater network of destinations, while also reducing unnecessary ultra-short-haul flights.
This could be done by increasing the level of free allowances in their place elsewhere in the airline’s network to areas that do not have convenient rail connections. 1.10.
The EU should engage with European works councils (EWCs), sectoral social dialogue committees and other joint forums, such as the Aviation Roundtable, on the continued impact of the revised ETS throughout its implementation.
Particular consideration should be given to social dialogue with workers and to understanding the needs and concerns they have in relation to sustainable aviation. 1.11.
The special status of EU outermost regions should be retained and such regions should be exempt from the ETS as per Article 349 TFEU, which allows for derogations from the application of EU law in these regions.
2.
General comments 2.1.
We welcome the Commission’s initiative amending Directive 2003/87/EC as regards aviation’s contribution to the Union’s economy-wide emission reduction target.
While not the largest emitter of emissions in society or indeed in transport, aviation and all its stakeholders must play their part in helping us achieve a sustainable aviation industry and reach our climate objectives, as outlined in the Paris Agreement and in the ‘Fit for 55’ package. 2.2.
Through such initiatives, stakeholder engagement and social dialogue, many of the social and economic threats to workers in the aviation sector can be mitigated, and we would welcome the Commission’s efforts to ensure that all stakeholders, in particular trade unions and EWCs, are engaged on the topics of climate change and just transition throughout the passage of this proposal, as well as on all future work on sustainable aviation.