Lufthansa's policy brief is a must read in all its' splenetic glory and is just a virulently anti-ETS rant.
Pleading for a larger free allowance because of the April 15th - 21st 2010 volcanic ash incident must be the first time in recent aviation history that an airline has asked, Oliver Twist style, for more CO2. In the area directly affected by ash Eurocontrol tell us there was a 67% reduction in flights over this 7 day period and a further 20% reduction outside. For an individual airline the impact on CO2 is unlikely to have been hugely significant - get over it Lufthansa, please. What next - add backs for snow cancellations?
We understand that applications for free allocations under the current benchmark are running at 95%+ in most major countries; the few states running late in some aspects are now running hard to keep up; if Lufthansa wants to be seen as an efficient, properly-run business with the interests of both its shareholders and the environment to the fore, it could usefully ensure that Germany's ETS mechanics are up-to-speed. This is the most practical way for Lufthansa to avoid the supposed ETS implementation related difficulties it harps on about.
And Lufthansa's actual CO2 emissions rose 10.1 per cent to 26.6 million tonnes in 2010 from the year before anyway, a less than sparkling performance.
Other nation's airlines may moan and threaten non-compliance but they will all end up either complying or being fined or clamped in extremis. The authorities in France, the Netherlands and Germany are responsible, for example, for most Chinese flights into Europe and we would encourage them to take a robust line with Chinese airlines - I would happily volunteer to fix a clamp to the nosewheel of the first Chinese 747 without the appropriate paperwork or seeking to dodge fines!
We know Lufthansa has an extremely knowledgeable and efficient in-house team working away at monitoring and verification - they are even selling their systems to other airlines; they know all about carbon pricing/markets and offset purchasing too; and they are analysing future ETS business impacts and yield management forecasting down to the last €cent.
Their briefing tells us that in 2012 they will face ETS costs of "up to €350 million" (this includes monitoring and verification start up costs)or to put it another way a tiny, tiny €3.9 per passenger (2010 Lufthansa group passenger numbers 90.2 million).
And the number of potential Lufthansa passengers who will fly miles further and for much longer on Emirates via Dubai to pocket €4 will in fact be somewhere in the range zero to none.
The 2 EU Member states whose ETS activities we follow most closely, the UK and France, have small but dedicated and highly professional teams of Government and Agency officials working very hard and effectively to deliver an admittedly complex scheme to tight unmissable deadlines, as does the European Commission too.
We are in no doubt that all the other Member States will sort themselves out in time to deliver a workable Aviation ETS.
But as Lufthansa's 2010 figures prove, controlling and reducing a major airlines' CO2 emissions needs a range of measures including adding the price of carbon to tickets. Quite simply,if you can afford the price of a ticket, you can afford the cost of carbon.
If Lufthansa truly want a fair and equitable global market-based option that works they should be actively campaigning for the EU Aviation ETS to become the worldwide model. Somewhat strangely perhaps, they aren't.
Aviation Environment Federation