Airlines International Representation in Europe IRE values the opportunity to provide insights on the draft Implementing Regulation that aims to integrate non-CO2 emissions from aviation within the EU Emissions Trading System (ETS) Monitoring, Reporting, and Verification (MRV) framework starting in 2025.
While CO2 emissions and their climate impacts can be estimated with high precision, calculating the effects of non-CO2 emissions involves complex modelling and assumptions. These estimations
depend on various factors such as flight paths, weather data and fuel composition. Due to the inherent uncertainties and assumptions in these parameters, accurately assessing the impact of
non-CO2 emissions for individual flights is highly challenging.
AIRE emphasizes that scientific consensus on the climate effects of non-CO2 emissions has not yet been established. Consequently, it remains unclear how the proposed data reporting requirements will advance scientific understanding. Therefore, AIRE’s feedback should not be interpreted as an endorsement of the non-CO2 MRV within the EU ETS framework.
