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Urgent!
To All U.S. Business Jet Operators

Just the thought of reading another piece on the European Union – Emissions Trading Scheme (EU-ETS) might cause premature eye closure prior to deep sleep - but if you can manage to read to the end of this- it might save you fines and possibly aircraft forfeiture. So get moving right now- and fill in the initial paperwork!

Despite the European Business Aviation Association (EBAA)- NBAA and many other business aviation organizations fighting this EU-ETS carbon credit program- the fact is that if you operate privately an aircraft with an MTOW of more than 5.7 tons to Europe- carbon trading is going to happen to you.

“What some don’t seem to appreciate is that if they’re a non-commercial flight- operating an aircraft above 5.7 tons and fly to Europe just once- then they are involved in EU-ETS-” emphasized Brian Humphries- President and CEO of EBAA.

He says even though registration should have taken place before January 2010 the EU authorities are not going to get tough yet- as their approach at the moment is “better late than never”. But “don’t push your luck” is probably going to become more realistic as implementation gets closer. The urgent message is: “Get registered now!”

ACT NOW - REGISTER
Even though the legislation is regarded across the industry as being similar to using a green sledgehammer to crack an already low emitting nut- the clock has not only started but the ETS set-up phase has been running since last year. From January 1st this year- operators should have started their emissions monitoring- reporting and verification program.

2010 is regarded as the operators’ data bench-marking year. Data collected then needs to be verified by the spring of 2011- and then in 2012 - the first trading year - operators will have to handover a set of allowances that cover their emissions. EUETS emissions can’t be paid in money – they have to be paid in emissions allowances (or carbon credits) - so one way or another you’re going to be involved in a carbon trading program.

The complication is that no one is going to know what the formula of tons/kilometers to one CO2 ton allowance will be until September 2011. All returns have got to be checked at the European level before allowances can be paid out. So 2011 will be a dummy-run year and it will be like using Monopoly money that the EU authorities have given you. However- what we can be sure is that- whilst the airlines will get the great majority of their allowances free- in Business Aviation we won’t- so from 2012 you’ll be buying carbon credits in an auction- with your own money.

EBAA CONCERN
Humphries is more than a little concerned that many U.S. business jet operators aren’t registering for EU-ETS- even though all companies that have operated to European Union countries since January 2006 should be on the list of an EU State.

“There are a lot of people still not signed-up-” said Humphries- explaining that the U.K. list has over 1-000 names on it- but is still 30% short of being fully signed-up. This includes U.S. operators as well as others from around the world that have flown into the UK since 2006.

“You need to check on the Eurocontrol- or European Commission website to find out if you’re on a list and to which country you’re allocated-” Humphries added. “Eurocontrol should have allocated you to the country to which you most regularly operate. So if you’ve only ever made one trip to Europe in the past you should have been allocated to that country.”

FACE IT - IT’S HAPPENING!
Humphries reckons that many U.S. operators think even now that EU-ETS won’t affect them or it will never happen. “I think they’ve heard the posturing - “the U.S. will never accept this”- or “why should the U.S. send money to Europe for trans-Atlantic flights”. These people are hoping it will all go away- and so do I. But it won’t go away by the implementation date of January 1st- 2012.”

His message is clear- “If you don’t want to be fined and you don’t want to risk losing your aircraft- just do what you have to do and start the simple registration process. Submit a plan which can be very simple- especially if you’re a low emitter using Eurocontrol’s EU-ETS Support Facility.” Humphries was particularly disappointed and worried by the very small attendance at the NBAA (Atlanta) EU-ETS session- which in previous years had been well attended.

“This year there were about 19 people there; six were staffers- about five were from the OEMs and I think only two operators attended - and they were probably already up to speed on the issue. It’s all very worrying!”

THERE TO HELP
Further- Humphries even had some people say to him- “We’re not going to come to Europe anymore because it’s going to be too difficult”.

“Our aim at EBAA and NBAA is to help people circumnavigate these obstacles and we’re fighting hard to make it as affordable- and as simple as we can - but it’s a real struggle.

“When it comes to the carbon trading element- operators will have to buy a minimum of 500 tons of CO2 offsets- which is like saying- ‘I only want a loaf of bread and then to be told you’ve got to buy 500.’ So people are going to have to go through third party organizations- which is totally unsatisfactory.

We’re here to help people get through this process and longer term we hope to make the system much better-” he promised.

AVOIDANCE ISSUES
To avoid EU-ETS Humphries agrees that some operators might even prefer to fly to a nearby non-EU country and charter locally to final destinations. But he says this attitude would seem to defeat the whole concept of using time-saving business jets.

“Whichever way you look at it- we’re already good performers; we’ve reduced emissions by 40% over the last 40 years- and the engine manufacturers have committed to a 2% improvement per year through to 2050. When you look at the Eurocontrol figures- we are 7% of the traffic and less than 1% of emissions so we’ve got a darn good track record and we don’t deserve to be singled out for this unfair treatment.”

Humphries went on to explain that commercial business jet operators (holding an Air Operator’s Certificate) can be more relaxed as they would have to produce either 10-000+ tons of CO2 per annum- or operate more than 243 flights per four months into Europe to exceed the cap.

“If you say that an average small business jet emits two tons per hour- that’s the equivalent of 5-000 hours - and since most business jets fly 400-500 hours per year- they’d have to have a fleet of 10 aircraft to exceed that figure- all- of course- operating to Europe. So most U.S. commercial operators won’t have to participate.”

HUMPHRIES’ SIMPLE MESSAGE…
“My message is really quite simple-” Humphries promised. “Get things done that you have to- then watch this space: We expect Eurocontrol’s EU-ETS Support Facility verification will be very simple. They’re talking about a one-off verification for most very small operators.

“One of the big worries is that the admin cost for small emitters is high. In the U.K. for a small emitter - emitting- say 50 tons of CO2 annually - after registering- they’re going to end up with admin costs twice that of the cost of the CO2. It’s a thoroughly- thoroughly bad law and in the longer term we in the EBAA and others are fighting very hard to get it changed so there will be a de minimus threshold for all operators.

“This will not happen by January 1st- 2012- though- so you’ve got to enter the program. Hopefully - say by 2015 - we will have got a bit of sense into the process-” he concluded.

ADVICE AND HELP
Service providers- including Air Routing International/Rockwell Collins and Universal Weather and Aviation are already offering advice and help on EU-ETS. Universal’s excellent EU-ETS tools- templates- FAQs and guidance can be found at www.eu-ets.aero.

You can also find Universal Weather’s Adam Hartley discussing FAQs on EU-ETS- the September issue of World Aircraft Sales Magazine (p110) or online at
http://editionsbyfry.com/Olive/ODE/WAC/Default.aspx?href=WAC/2010/09/01&pageno=110

NBAA (
www.nbaa.org) and EBAA (www.ebaa) are also sources of help and advice.

To find out if you’re on a list and to which country you’re allocated- check on the European Commission website at http://ec.europa.eu/environment/climat/aviation/operators_en.htm


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