NGOs from across Europe send open letter to EU ministers, asking for proper action on aviation CO2

The inclusion of international flights into the EU’s carbon market (the EU ETS) was one factor that created momentum for a global, rather than regional, measure to address aviation emissions. Recognizing Europe’s potential importance in trying to get progress in the ICAO negotiations towards a global MBM (market based measure), open letters from 15 NGOs across Europe have been sent to EU’s transport and environment/climate ministers. The letters ask them to do more in getting aviation CO2 emissions cuts.  ICAO is aiming to adopt a global MBM to address some of the rapidly-rising emissions from global aviation,at its 2016 meeting. In theory, if ICAO does not come up with a sufficiently effective MBM, the EU will be asked to bring back its ETS measure. But with just one year till the scheduled adoption, the EU is punching below its weight at the negotiations, and there are concerns the ICAO’e level of ambition on CO2  is far too low. The NGO letters say that to keep aviation CO2 emissions down, the subsidies that European aviation enjoys, including tax-free status of fuel and no VAT, subsidies to non-viable regional airports and legalising operating aid to airlines, need to be cut.



Growing expectations on EU ministers to promote aviation mitigation

04 May 2015

The inclusion of international flights into the EU’s carbon market was one factor that created momentum for a global, rather than regional, measure to address aviation emissions. Recognizing Europe’s potential importance in the ongoing negotiations towards a global market based measure, open letters from fifteen NGOs across Europe were sent to EU’s transport and environment/climate ministers, calling on them to step up in promoting emissions reductions from aviation – a fast-growing and polluting sector.

The International Civil Aviation Organization (ICAO) intends to adopt a global market-based mechanism to address some of the rapidly-rising emissions from the aviation sector in its 2016 meeting. In April it held five regional meetings, in Lima, Cairo, Nairobi, Singapore and Madrid, to engage interested parties that have not been deeply involved in the measure’s development to date.

The inclusion of international flights into the EU’s carbon market was one factor that created momentum for a global, rather than regional, measure. The current temporary suspension of international flights in the EU ETS  [Emissions Trading System] gives the EU potentially a lot of influence in the negotiations, as the exclusion is depending on whether the future GMBM [Global Market Based Measure] will have at least equivalent environmental integrity to the EU ETS for it to be acceptable to Europe.

If the GMBM is deemed to lack sufficient environmental integrity, the EU will be asked to bring back its ETS measure.

However, with about one year to go until the scheduled adoption, the EU is punching below its weight at the negotiations. This is partly due to the lack of coordination between Member States, and between transport ministries, which have the aviation expertise, and environment ministries, where knowledge of carbon markets tends to reside.

Moreover, there are concerns on the overall adequacy of the ICAO’s emissions control ambition – it is currently not consistent with limiting warming to 2ºC and lacks carbon budgets for 2030 to 2050.

While a fair GMBM is important and could be a source of new public climate finance, it must not replace complementary rigorous technical and operational measures, such as an ICAO CO2 standard for new aircraft.

Another essential element in tackling aviation emissions is to cut subsidies to the aviation industry in the EU, including removing the tax-free status of fuel and the lack of VAT, relics from the 1940s, as well as putting an end to subsidizing non-viable regional airports or legalizing operating aid to airlines.

ICAO estimates that fuel demand in the international aviation sector will rise from 187MT [million tonnes] in 2006 to 461Mt in 2036. This would bust the global carbon budget and amplify the existing risks from climate change.

The EU has already taken an important step by pushing for the inclusion of text in the UNFCCC [United Nations Framework – Convention on Climate Change] process to include international aviation and shipping in the Paris deal at the end of the year.

Building on this momentum, EU Member States now need to show a unified voice to push for a robust deal towards the adoption of a global market based measure under the ICAO process.


The letter:

Letter to EU Environment and Transport Ministers on aviation emissions

16 Apr 2015





Dear Minister,

2015 is a key year for global efforts to combat climate change and keep warming under 2ºC. Aviation, which currently accounts for 5% of global warming and is the most carbon intensive and fastest growing transport mode, must play a central role. Its CO2 emissions, approximately equal to those of Germany, are predicted to grow by up to 270% between 2010 and 2050. Its fossil fuel consumption is set to double by 2036, greatly undermining efforts to decarbonise the global economy.

Since 1997, the International Civil Aviation Organisation (ICAO) have failed to take any measures to reduce emissions, which more than doubled over that period. However, ICAO is currently considering an offset mechanism, which we consider deeply inadequate because of its likely minimal environmental effect. ICAO’s Dialog on market based measures in Madrid on 27-29th April aims to expand the scope of the discussion and engage more people in the development of this market mechanism and is an opportunity for Europe to address the mechanism’s inadequacies.

Aviation emissions must be reduced through rigorous technical and operational measures complemented by fair market-based mechanisms. Such mechanisms may also offer an important source of new public climate finance. Aviation’s tax-free fuel and VAT status works at cross purposes to emissions reduction and must be phased out in Europe. There is no place for a proliferation of subsidies to non-viable regional airports or for legalising operating aid to airlines serving them in a vain attempt at profitability. The SES must be properly implemented by member states.

European effectiveness at ICAO is being undermined by a lack of common purpose. The EU must establish a common position on the key environmental and framework issues and work proactively and in tandem to achieve them. In the context of Europe’s own 40% emissions reduction commitment by 2030, member states have the choice of pressing for greater global ambition or implementing further measures at the European level.

European legislation requires that should ICAO fail to produce an outcome as environmentally effective as the ETS, then the original ETS scheme will return in full force in 2017.  Any intra-EU system must not be based on offsetting.

We therefore request that you:

  • Ensure that at the forthcoming Madrid Dialogue ministries dealing with both transport and carbon market issues are represented, to facilitate inter-ministerial understanding and cooperation, and a genuine focus on the environment. Europe has too often taken a passive position.
  • Propose that ICAO agree ambitious, legally binding, emissions reduction carbon budgets for 2030 and 2050 consistent with limiting global warming to well below 2ºC and work to agree implementing measures
  • Preserve EU language on international aviation and shipping emissions in the UNFCCC negotiation text is preserved and strengthened in the Paris Agreement at the end of this year
  • Instruct EU representatives to work to ensure an ICAO CO2 standard for new aircraft that has a real effect. Current plans will effectively have no environmental impact for a generation.

We hope that you share our concerns on the need to address international aviation emissions and look forward your response.

Further information is included in the attached briefing.

Yours sincerely,

Aviation Environment Federation (AEF)

Amigos de la Tierra España

Bund für Umwelt und Naturschutz Deutschland

Carbon Market Watch

Climate Concept Foundation

The Civil Affairs Institute (INSPRO)


Leave it in the Ground Initiative (LINGO)

Levegő Munkacsoport – Clean Air Action Group
Natuur en Milieu (N&E)



Réseau Action Climat France (RAC-F)
Transport & Environment (T&E)

WWF European Policy Office



Carbon Market briefing 

? April 2015

Front Page - Briefing