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Greenhouse gas emissions from international aviation and allocation options 11 Conclusions11.1 Availability and quality of the reporting by Parties to the UNFCCC on emissions from international aviationEmissions from international aviation are complicated to estimate because the distinction between fuel used for domestic and international purposes is difficult. Another problem is the separation of fuel consumed by military aircraft from fuel consumed by civil aircraft. Of the 32 Annex I Parties to the UNFCCC, 12 Parties report to the UNFCCC their CO2 emissions from domestic aviation in all the years from 1990-1999 while 16 Parties report CO2 emissions from international aviation in the period. Fewer Parties report the other emissions species from aviation for the whole period 1990-1999. Thus, currently there seems to be an inadequate geographical coverage of the data reported to the UNFCCC by Annex I Parties. The UNFCCC Secretariat has requested CAEP to explore opportunities to examine and improve the quality of data reporting and comparability of aviation bunker fuel data [UNFCCC 2002a]. CAEPs Steering Group Meeting in September 2002 agreed that the ICAO Secretariat should take the necessary steps to organize a "scoping meeting", involving the UNFCCC Secretariat, the rapporteurs of some of CAEPs working groups and experts on emissions inventory and data reporting. This initiative may bring new insights of relevance on the topic. Eurostat and the International Energy Agency are preparing a joint manual on annual energy statistics to help Member States' statistical authorities in filling in the energy statistics questionnaires. Eurostat also organises training workshops for officials from these authorities to discuss problems in data collection and reporting. In a recent ECAC initiative European countries that participate in ECAC are encouraged to begin using the Detailed Corinair Methodology for calculating aircraft emissions. This may improve the ability of European countries to separate better emissions for international air transport from emissions for domestic air transport. Another recent European initiative has been launched in a cooperation between the European Environment Agency, Eurocontrol and Eurostat to improve the data availability involving the use of a database supplied by Eurocontrol on actual flights performed in Europe and the use of the detailed Corinair emission calculation methodology. This effort may offer the opportunity to compare the data reported to the UNFCCC by European Parties to ECAC to the data calculated by EEA, Eurocontrol and Eurostat. Eurostat finances specific projects in the Member States that aim at eliminating differences in energy data reported to Eurostat and those used for the calculation of CO2 emissions reported to the UNFCCC. This work will also improve reporting of fuel consumption for international aviation. The projects will examine the energy data used in the submissions for the years 1990, 1995 and 2000, identifying and explaining the differences. Besides the need to improve the methodologies for separating emissions from international aviation from emissions from domestic aviation there is another related question that is applicable to the reporting of aviation emissions in the European Union: Since the European Union has ratified the Kyoto Protocol the question arises whether the EU inventory should merely represent the sum of national inventories or if international intra-EU flights should be regarded as "domestic" in the EU inventory. If it is decided that the EU inventory should include international intra-EU flights as domestic these emissions have to be separated from the emissions reported as international by EU Member States. The emission calculation work currently under way in the cooperation between the European Environment Agency, Eurostat and Eurocontrol may be used to produce the data needed for that process. Another problem that may remain in Europe is whether countries that have overseas territories should include flights to these areas in their national inventories or if these emissions should be reported as domestic emissions. According to the IPCC/UNFCCC reporting guidelines, administered territories should be included in national inventories, but for many countries they are not at present. 11.2 Availability and quality of inventory modelsCurrently Parties to the UNFCCC can use different methodologies of varying detail in their reporting of aviation emissions to the UNFCCC. A recent ECAC initiative aims at encouraging European countries that participate in ECAC to begin using the Detailed Corinair Methodology for calculating aircraft emissions. This may increase comparability and accuracy in the reporting from these countries to the UNFCCC. Another recent initiative from the European Commission, Eurostat and EUROCONTROL, the so-called TRENDS project, may also improve the data material and may also give the European countries the possibility to crosscheck their reporting to the UNFCCC to the data from Eurostat. The TRENDS initiative also opens the possibility of calculating fuel use and emissions separately for intra-EU flights. Such data may be needed for the EU emission inventory submitted to the UNFCCC. In the current situation only Annex I countries report emissions from aviation to the UNFCCC, but around one third of the CO2 emissions from international aviation bunkers in 1999 relate to fuel sold in non-Annex I countries that have not yet agreed to reduction targets under the Climate Convention. Much of the fuel sold in non-Annex I countries may be consumed by airlines registered in Annex I countries or may be consumed by airlines transporting passengers and goods originating from Annex I countries. In case CAEP/ICAO intends to set up an emissions trading scheme the development of a yearly updated global inventory may be useful for calculating the total emissions from aviation, and more exact figures than those available today may also be needed to set up the system. A few global inventories have been conducted, but only for the year 1992, and these inventories are neither as detailed as for example the detailed CORINAIR methodology in their use of aircraft categories and emission indexes and neither do they contain accurate data on flights actually performed by all airlines globally. A working group "Alternative Emissions Methodology Task group" has been set down by CAEP aiming at providing a better understanding of cruise emissions from aviation. Similarly, the European Commission is currently funding a programme in this area called "NEPAIR". At this time, both projects are seeking to establish methodologies, but not standards, that could be used for certification of aircraft engine cruise emissions, that may be ready by 2003. Currently, the ICAO Emissions Databank only contains certificated data for Landing and Take Off (LTO) emissions but these new initiatives may in the future lead to recommendations for the development of standards for engine emissions at cruise [NEPAIR 2002]. 11.3 Availability and quality of airline dataThe fuel intensity estimates currently reported by different airlines are not directly comparable because of the differences in reporting methodologies. One example is that some airlines subtract a part of the fuel consumption which is attributable to freight transport in passenger aircraft, whereas others include this use in the estimate for the specific fuel use per revenue passenger kilometre. The division of fuel use between passengers and freight is not straightforward. In the United States all airlines of a certain size are required by law to report their operating statistics to the Department of Transportation (the socalled "Form 41" arrangement). Therefore, in the United States, a comprehensive database exists with data for the fuel consumption of airlines and their aircraft spanning back several decades. This type of data can be used to make comparisons between airlines and for indexing their fuel efficiency. Such data are currently not being systematically reported to the same detail to governments, ICAO or elsewhere by airlines in other countries, although most airlines almost certainly gather such data for internal purposes. One interesting question is whether it would be possible to establish some sort of global reporting requirements for all the World's airlines in line with the US "Form 41" establishment. Since ICAO and CAEP are currently investigating possibilities for setting up voluntary agreements with airlines on reducing their specific emissions of CO2 that process might involve setting up a scheme for airline reporting of fuel consumption and emissions. Furthermore, ICAO and CAEP are currently investigating the possibility to set up a global system for emissions trading. Such a system may come to involve the setting of an emission cap and the allocation of certain emission quotas to airlines and may also involve new reporting requirements for airlines. Even though airline fuel consumption could be estimated using bottomup modelling, for example using the Corinair-model, actual fuel consumption data from airlines may be needed because airlines might not be likely to accept being accredited for modelled fuel consumption data. At least at present, the models that have been constructed to calculate emissions from air traffic on a global scale do not contain a comprehensive database on flights actually being performed and furthermore relies on calculating fuel consumption and emissions by using less detailed aircraft categories than those used in the detailed CORINAIR methodology. Furthermore, all the models constructed to date are disadvantaged by not containing detailed information on the actual passenger loads and freight loads transported by the aircraft. These loads may become relevant for example in the case that airlines should become required to reduce their emissions per passenger kilometre and per freight tonne kilometre in a voluntary scheme. Detailed data on the passenger and freight loads may also become necessary for some of the more sophisticated models for allocating emissions from international aviation to Parties. However, these sophisticated models of allocation currently do not seem to be the most likely to be chosen if Parties to the Climate Convention should agree upon implementing an allocation option. 11.4 Allocation of emissions from international aviationParties to the UN Climate Convention have not yet been able to agree upon a methodology for allocating emissions from international aviation to Parties. Therefore, these emissions are not included in the national emission inventories that are to be reported to the UNFCCC by Annex I countries, but are reported separately under international bunkers in conjunction with emissions from international marine transport. SBSTA has considered the following options for allocating emissions from international aviation [UNFCCC 1996a]:
In 1996 SBSTA 4 concluded that options 1, 3, 4, 5 and 6 should be the basis for the further work and that with respect to option 1 (non-allocation) the responsibilities of the international community to address issues related to international bunker fuels should be recognised. Options 2, 7 and 8 were discarded by SBSTA for different reasons. The main reason for discarding option 2 is lack of equity because emissions are not allocated in proportion to the amount of aviation activities performed by each Party. The problem with option 7 is that the data needed on the origin of passengers and freight simply is not generally publicly available. Finally, option 8 was discarded because of its inadequate global coverage since all emissions above international waters are not allocated to Parties under this option. By 1999, in a statement to SBSTA, the European Community stated that any decision on the inclusion of emissions from international bunker fuels in the national inventories of Parties (i.e. on allocation) should enter into force during the second commitment period. Based on the conclusions of SBSTA 4, the EU proposed a twin-track approach (main options I and II). Option I is not to allocate emissions from international aviation in the national inventories of Parties (option 1) as in the current situation. Limitation or reduction of emissions from international aviation would be under the general responsibility of the international community to be pursued through ICAO. The EU may consider option 1 (no allocation) further, if ICAO makes demonstrable progress, taking into account the overall emission reduction target of the Kyoto Protocol. Option II is to include emissions from international aviation in the national inventory of the Parties. With regard to the allocation options (options 3, 4, 5, and 6), EU propose that the SBSTA should compare and discuss these with a view to being in a position to reach agreement on one option by 2005. The remaining question seems to be whether it may be possible to reach an agreement on the allocation issue before 2005. Furthermore, recent developments suggest that ICAO may be heading towards investigating further the potential use of an open emissions trading scheme for aviation, allowing the aviation industry to buy emission permits in other sectors. It has recently been pointed out by the UK Royal Commission on Environmental Pollution that if an emissions trading scheme is implemented, emissions from international aviation would have to be included in national greenhouse gas inventories of Parties to avoid double-counting of emission reductions attained in other sectors [Royal Commission on Environmental Pollution 2002]. Therefore, on the longer term, it seems that emissions from international aviation may have to be allocated to Parties also in the case where emissions reduction is pursued through ICAO. SBSTA and the European Commission seem to agree that any allocation option chosen should be consistent with the 'polluter pays' principle and therefore should be equitable. The problem is that, in the case of international aviation activities, it is not always clear who should be considered as the 'polluter'. Furthermore there is the problem that it should be possible to ensure the availability and accuracy of the data required for allocating emissions. Option 3, allocation to the Party where the fuel is sold, seems to be the easiest way to allocate emissions from aviation because the data are to a wide extent already available. Furthermore, a comparison of options 3, 5 and 6 show that, for most countries, the different methodologies used for each option do not produce radically different results. The main problem with the data reported by Parties to the UNFCCC on fuel consumed for international aviation, is that Member States are having difficulties in separating fuel consumed for domestic and international purposes. The separation of fuel sales into domestic and international does not seem to be necessary if emissions from international aviation are to be included in national totals according to where the fuel is sold. However, option 3 does not take into account that aircraft can tanker extra fuel for a given trip. Some countries that sell aviation fuel at relatively low prices may therefore be disfavoured by option 3 as compared to options 4 (allocation to the nationality of airlines), 5 (allocation to the country of destination or departure of aircraft) and 6 (allocation to Parties according to the country of departure or destination of passenger or cargo). Option 5 may solve the tankering problem but would require that Parties use bottom-up models to calculate fuel consumption. Option 6 is disfavoured by the fact that it would require even more complicated models and data details than option 5. Options 3, 5 and 6 disfavours countries with a high level of aviation activities (for example countries that house large international hub airports) and this can cause equity considerations in cases where a large portion of the passengers and the freight is transported through the country in transit. Option 4 is disfavoured by the fact that countries do not currently gather data on the fuel consumption of national airlines. However, such data may be relatively easy to collect. The main disadvantage of option 4 seems to be that it does not necessarily always apply the 'polluter pays' principle because countries with large national airlines would be held responsible for a large proportion of global aviation emissions, even if many of the flights does not depart or arrive within the country itself. However, option 4 may involve that a higher share of the emissions from international aviation will be allocated to Annex I countries than what is the case for options 3, 5 and 6. From an equity point of view option 4 could be considered more equitable for non-Annex I countries due to the fact that much of the fuel sold for international aviation in these countries may actually relate to air travel performed by people living in Annex I countries. Finally it should be mentioned that option 7 (allocation to the country of origin of passengers or owner of cargo) is probably the option which is most in line with the "polluter pays" principle and would most likely be favourable to non-Annex I countries and to countries that house large international hub airports, but this option has been discarded by SBSTA due to its substantial data requirements.
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