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Preparing for Contrail Reporting Requirements in European Union
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EU could impose a tax on non-CO2 aircraft emissions
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In the last two years, 4Air helped offset more than 2.5 million metric tons of CO2 from more than 550,000 flight hours.
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Sustainability company 4Air is gearing up for aircraft contrail reporting under a 2025 EU mandate that will require aircraft operators to “report once a year on the non-CO2 aviation effects." This includes emissions of nitric oxides (NOx), soot particles, oxidized sulfur species, and effects resulting from water vapor.

The EU will use this data to determine if contrails will be integrated into the EU Emissions Trading Scheme (ETS) by the end of 2027—in other words, potentially taxing a non-carbon emission under an existing carbon tax scheme. The cumulative net warming impact of contrails is somewhere between 100 percent and 500 percent of the warming impact of CO2 alone, depending on time of day.

In the last two years, 4Air helped offset more than 2.5 million tonnes of CO2 from more than 550,000 flight hours. The company helps private aircraft operators worldwide calculate and offset their impacts on the environment through its four-level rating system. The company also can connect users with available sustainable aviation fuel (SAF) with its live mapping tool, which currently shows verified locations where it can be obtained and gives carbon ratings to aviation facilities.

For customers attempting to navigate the minefield of the rapidly growing volume of aviation environmental legislation and regulation, including the potential for the integration of contrails into the EU-ETS, 4Air provides regulatory monitoring and compliance programs. This is particularly useful in Europe, where the related landscape is changing rapidly, according to Kennedy Ricci, 4Air president.

While the EU-ETS has been in place for nearly 12 years, additional policies are springing up on a national, local, and even individual airport basis, according to Ricci, creating an ever-changing and confusing regulatory landscape.

“EU countries are setting their own benchmarks and mandates for blending SAF and [imposing] carbon taxes or reporting obligations—all the way down to specific airports introducing their own blending mandates or carbon reporting requirements,” Ricci noted. Overall, he calls the European market “very nuanced” when it comes to emissions policy, citing regulations that either don’t accept “book-and-claim” carbon offset when it comes to SAF or only accepts it on a very limited basis.  

4Air is meeting the multi-layered, multi-jurisdictional regulatory challenge by developing an automated system that makes it easy for operators, both in Europe and elsewhere, to maintain compliance. “We’ve got programs designed to help you,” Ricci said. In Europe, 4Air maintains staff to monitor emergent policies and engage with rule-makers and operators.

With regard to contrails, official reporting guidance should be out within the next few months, Ricci said. Overall, he doubts this quilt of regulation is going to be streamlined any time soon.

“I think we are in an era of growing and emerging new regulation rather than an era of consolidating regulation, so unfortunately we’re going to keep seeing more and more localized regulation to support each country’s own [environmental] ambitions, even down to the level of individual airports with their own visions,” Ricci said. “It is adding a lot of complexity that just didn't exist two years ago in Europe at all, much less five years ago before Covid.”

Ricci believes Eurocontrol eventually will take primary responsibility for vectoring traffic around airspace where environmental conditions are ripe for contrail formation and that ADS-B will be used to assess whether a particular aircraft traversed the area and for how long.

He likened it to rerouting to avoid known areas of severe turbulence or icing but added that, like those two conditions, contrails come in degrees of severity, and traversing some areas of potential contrail formation will have little or no impact. But Ricci added that the result likely will be less disruptive than it sounds.

“We can help reroute some of those big hit flights, but it’s not like we have to do this for every single contrail-forming flight. In fact, I think for some of the data we looked at, it's fractions of a percent of the total number of flights that enter these types of [contrail-producing] zones. So it's a small number of flights that we have to look at and they're usually very thin adjustments—on the order of a 2,000-foot vertical adjustment,” he said.

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4Air is gearing up for aircraft contrail reporting under a 2025 EU mandate that will require aircraft operators to “report once a year on the non-CO2 aviation effects." This includes emissions of nitric oxides (NOx), soot particles, oxidized sulfur species, and effects resulting from water vapor.

The EU will use this data to determine if contrails will be integrated into the EU Emissions Trading Scheme (ETS) by the end of 2027—in other words, potentially taxing a non-carbon emission under an existing carbon tax scheme. The cumulative net warming impact of contrails is somewhere between 100 percent and 500 percent of the warming impact of CO2 alone, depending on time of day.

In the last two years, 4Air helped offset more than 2.5 million metric tons of CO2 from more than 550,000 flight hours. The company helps private aircraft operators worldwide calculate and offset their impacts on the environment through its four-level rating system. For customers attempting to navigate the minefield of the rapidly growing volume of aviation environmental legislation and regulation, including the potential for the integration of contrails into the EU-ETS, 4Air provides regulatory monitoring and compliance programs. This is particularly useful in Europe, where the related landscape is changing rapidly, according to Kennedy Ricci, 4Air president.

While the EU-ETS has been in place for nearly 12 years, additional policies are springing up on a national, local, and even individual airport basis, according to Ricci, creating an ever-changing and confusing regulatory landscape.

“EU countries are setting their own benchmarks and mandates for blending SAF and [imposing] carbon taxes or reporting obligations—all the way down to specific airports introducing their own blending mandates or carbon reporting requirements,” Ricci noted. Overall, he calls the European market “very nuanced” when it comes to emissions policy, citing regulations that either don’t accept “book-and-claim” carbon offset when it comes to SAF or only accepts it on a very limited basis.  

With regard to contrails, official reporting guidance should be out within the next few months, Ricci said. Overall, he doubts this quilt of regulation is going to be streamlined anytime soon.

“I think we are in an era of growing and emerging new regulation rather than an era of consolidating regulation, so unfortunately we’re going to keep seeing more and more localized regulation to support each country’s own [environmental] ambitions, even down to the level of individual airports with their own visions,” Ricci said. “It is adding a lot of complexity that just didn't exist two years ago in Europe at all, much less five years ago before Covid.”

 

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