The implementation of Europe’s emissions trading scheme (ETS) has begun amid widespread confusion on the part of the aircraft operators who stand subject to it and the government bodies responsible for running it. August 31 was supposed to have been the deadline by which operators had to register their plans for monitoring, reporting and verifying (MRV) carbon dioxide emissions from their fleet. However, despite the fact that ETS has undergone development for several years, it took the European Commission until
August 22 to publish a full list of operators subject to ETS and the list of national agencies in each of the 27 European Union states to which each individual operator must submit their plans.

The delay in publishing the list of operators prompted the UK’s Environment Agency to
suspend the August 31 deadline, and its German counterpart soon did the same. However, other EU states have not publicly given the operators assigned to them more time to file MRV plans, leaving them scrambling to complete the paperwork in barely a week.

Many non-European airlines–and especially those in the U.S.–object on principle to Europe’s unilateral cap-and-charge approach to controlling aircraft emissions. Some have even questioned its legality and continue to hope for a legal challenge. But the prospect of heavy fines and the possibility that authorities could impound their aircraft appear to have compelled all operators at least to register for ETS.
The requirement to actually start buying emissions credits does not start until January 2012. The process of monitoring emissions from existing operations by way of establishing benchmarks is due to get under way in January 2010, but before then European officials will feel pressure to prove the associated bureaucracy not as unwieldy as it appears to many in the air transport sector.
The EC list of operators, along with more information, appears on the following page on the EC Web site. More information on the ETS process also appears on the UK Environment Agency Web site.