Aviation EU-ETS Changes – Part 2: Covered Areas, Calculations and Exemptions

Aviation EU-ETS Changes – Part 2: Covered Areas, Calculations and Exemptions

This business aviation blog post continues from our article last week, titled: "Aviation EU-ETS Changes – Part 1: Good News from the European Commission."

Concerning the period 2014 to 2020, the European Commission (EC) proposes that the European Union Emissions Trading System (EU-ETS) continue to fully cover emissions from all flights between airports in the European Economic Area (EEA), including flights between airports in the EEA and airports in outermost regions of the EEA.

The following is an overview of what you need to know:

1. Geographic scope of the proposal

For the 2013 reporting year, the EC proposes EU-ETS requirements are applicable for flights between EEA countries. For the period 2014-2020, the EC proposes that EU-ETS cover emissions from all flights between airports in the EEA, including flights between airports in the EEA and airports in the outermost regions of the EEA – such as Iceland. Flights between EEA airports and airports in third countries would generally be covered in proportion to the distance travelled within European airspace. This proportion would cover the distance from 12 nautical miles (NM) from the farthest point on the outer coastline of an EEA territory to the EEA airport or arrival/departure point.

11/27/2013: Update by author

2. Emission calculations for 2013 and beyond

For 2013, small emitter calculators assist operators in determining reportable CO2 emissions. Tools for calculating CO2 emissions for 2014 and 2015 have not yet been created, but you’ll need to submit 2014 and 2015 CO2 reports by 2015. We are, however, still somewhat "flying in the dark," as CO2 reporting procedures for 2013-2015 are also unknown at this time. There’s no guarantee that the European Parliament will ratify this proposal and, if they do, to what extent.

3. Changes to small emitter tools

Going forward, if approved by the EC, small emitters will use the ETS support facility instead of a small emitters tool. This support facility provides more comprehensive calculations — as opposed to a small emitter tool that simply provides data based on NM and aircraft type. Emitters of less than 1,000 tons of CO2 (approximately 90% of global GA operators) will be exempt and will not need to submit emissions reports or purchase carbon credits. Operators with between 1,000 and 25,000 tons of CO2 emissions annually will use simplified carbon tracking and reporting procedures, such as the ETS support facility. Keep in mind, however, that none of these proposed changes/regulations have been approved at this point, and C02 reporting procedures for small emitters are not known at this time.

4. Operator recommendations

Contact your 3rd-party provider to gain more insight on proposed EU-ETS changes and how these developments may impact your operations. Best practice, for the time being, is to log all flights to, from, and within the EU until more information is known. Although we’ve not seen any EU enforcement to date for non-compliance, it’s unknown what will happen in the future in terms of compliance/enforcement. Those operators who choose not to track EU-ETS-related flight legs may be leaving themselves open to future fines, although we haven’t seen any such fines yet.


Recent changes impacting EU-ETS are good news for small emitter GA operators who make up over 90% of GA operators worldwide. Small emitters should be able to look forward to reduced overall costs and significant reductions in time involved, in terms of complying with EU-ETS mandates, if these aspects of the proposal are approved by the EC. As the EC’s EU-ETS program develops over coming years, there will likely be some level of flight tracking required regarding CO2 calculations. The details of all of this, however, are in the future and unknown at this time.


If you have any questions about this article or EU-ETS regulations, contact me at adamhartley@univ-wea.com.