Following the Brussels Contrails Conference on 19–20 October, one issue stood out: although recognition of contrail mitigation’s potential is increasing, the aviation ecosystem is not yet fully equipped to translate it into consistent, scalable operational action.
As Sian Andrews of NATS highlighted,contrail mitigation can be prioritised during periods of low traffic density, such as quieter periods in domestic airspace. In busier airspace, however, prioritising contrail avoidance remains challenging for air traffic controllers (ATCOs) with the tools currently available.
- Enabling implementation alongside incentives
A key message from the conference was the need to accelerate the development and deployment of contrail mitigation tools. Both, Carlos López de la Osa ( T&E ) and Marylin Bastin ( EUROCONTROL ) highlighted the importance of focusing incentives on promoting the right tools to be used by the aviation sector.
This is particularly relevant to the European Commission’s proposal to revise the EU Emissions Trading System (EU ETS), under which up to 3 million allowances are reserved until 31 December 2033 to incentivise aircraft operators to mitigate contrails.
The policy question is whether incentives directed at aircraft operators alone will be sufficient to deliver the intended outcomes if the operational capabilities required to support contrail avoidance are not yet fully in place.
Effective implementation depends on several interrelated factors: lack of scientific consensus, variability, differences between contrail prediction models, the need for reliable and consistent metrics, the operational complexity faced by ATCOs and coordination across the aviation value chain all need to be addressed.
Incentivising airlines to avoid contrails is not the same as enabling the aviation system to deliver contrail avoidance. For incentives to translate into meaningful results, policy must also support the tools, procedures and collaborative arrangements needed to integrate mitigation into day-to-day operations.
2. Cost-effectiveness must be considered in context
During the conference, contrail avoidance was discussed as one of the less costly environmental mitigations measures available to aviation. However, even if the additional cost is estimated at approximately 1.4%, this figure needs to be considered in the broader economic and regulatory context in which airlines operate.
The sector is already managing a growing range of environmental obligations, including Sustainable Aviation Fuel (SAF) mandates, anti-tankering measures, flight emissions labelling, CORSIA and the UK Emissions Trading Scheme (UK ETS), among others.
For some airlines, these requirements are managed by very small sustainability teams, sometimes with just one person responsible for coordinating multiple regulatory frameworks, reporting obligations and implementation processes.
The question, therefore, is not simply whether contrail avoidance is comparatively affordable. It is whether airlines have the staffing capacity and expertise to implement it, and whether the necessary tools and operational support are available.
Cost-effectiveness alone does not guarantee operational feasibility.A measure may be economically attractive in principle yet remain difficult to implement in practice within the operational and regulatory constraints of the sector.
3. Aligning incentives with operational readiness
The challenge is not a lack of climate ambition, but rather ensuring that policy objectives, technological development and operational implementation advance in parallel.
As discussions on the revision of the EU ETS continue, particular attention should be paid to the design of the proposed incentive mechanism. Beyond rewarding AOS for contrail mitigation actions, the mechanism should address existing barriers to implementation by supporting the development and deployment of the tools required to make mitigation viable at scale.
The effectiveness of the mechanism will depend not only on the incentives it provides, but also on the aviation sector’s ability to respond to them in practice. This requires a coordinated approach involving airlines, pilots, air traffic controllers, technology providers, regulators and policymakers, with their respective roles and operational constraints adequately reflected in the policy framework.
Ultimately, the objective should be to establish the conditions necessary for contrail mitigation to be implemented reliably, assessed credibly and scaled effectively, ensuring that policy ambition translates into demonstrable climate benefits.


