Carbon Market Watch reply to the European Commissionʼs Inception Impact Assessment for updated rules to the EU ETS aviation coverage

Carbon Market Watch urges the European Commission to adopt the most ambitious options for the EU ETS aviation coverage, specifically advocating for full coverage of emissions and 100% auctioning of allowances from the regulation's adoption. The organization criticizes CORSIA as an ineffective climate strategy and warns that replacing EU ETS coverage with CORSIA would reduce climate ambition and revenue. Additionally, the document calls for the regulation of non-CO2 effects, which are estimated to multiply the global warming impact of aviation CO2 by 2-4 times.

• Carbon Market Watch identifies 'Option 1 (full coverage of emissions under the EU ETS)' as the most environmentally sound choice, arguing that any options resulting in a 'de facto step-back' from current coverage are unacceptable.
• The organization advocates for 'full auctioning from the adoption of the regulation' (Option 1), stating that other phased-in auctioning targets are too slow and that the existing EU ETS infrastructure allows for a rapid shift to 100% auctioning.
• CORSIA is characterized as an incredible climate strategy that is likely to be oversupplied and relies on credits of 'questionable environmental integrity', such as CDM and forestry credits.
• The document asserts that non-CO2 effects are significant, typically multiplying the global warming impact of aviation CO2 by 2-4 times, and urges the Commission to regulate these impacts through mechanisms like NOx charges.
• The report argues that free allocation of allowances violates the 'polluter pays principle' and has led to 'windfall profits' for the aviation sector without effectively incentivizing emission reductions.
• Evidence from a 2017 assessment suggests that EU ETS compliance costs are very low, estimated at 0.3% of airlines' total operating costs, and that carbon prices have not been high enough to cause significant leakage or demand reduction.

APA

Carbon Market Watch (n.d.). Carbon Market Watch reply to the European Commissionʼs Inception Impact Assessment for updated rules to the EU ETS aviation coverage. https://carbonmarketwatch.org/wp-content/uploads/2020/08/CMW-reply-to-aviation-EU-ETS-consultation.pdf

Chicago

Carbon Market Watch. Carbon Market Watch reply to the European Commissionʼs Inception Impact Assessment for updated rules to the EU ETS aviation coverage. n.d. https://carbonmarketwatch.org/wp-content/uploads/2020/08/CMW-reply-to-aviation-EU-ETS-consultation.pdf.

Wikipedia

{{cite press release |author=Carbon Market Watch |title=Carbon Market Watch reply to the European Commissionʼs Inception Impact Assessment for updated rules to the EU ETS aviation coverage |url=https://carbonmarketwatch.org/wp-content/uploads/2020/08/CMW-reply-to-aviation-EU-ETS-consultation.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{carbonmarketwatchndcarbon, author = {{Carbon Market Watch}}, title = {{Carbon Market Watch reply to the European Commissionʼs Inception Impact Assessment for updated rules to the EU ETS aviation coverage}}, publisher = {Carbon Market Watch}, url = {https://carbonmarketwatch.org/wp-content/uploads/2020/08/CMW-reply-to-aviation-EU-ETS-consultation.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }