ICCT Comments To An European Commission On An MRV For Aviation's non-CO2 Impacts

To: European Commission, 1049 Bruxelles/Brussel, Belgium
Date: 27 July 2024

Re: Non-CO2 MRV consultation
Dear Committee:
In May of 2023, the European Parliament and Council issued a directive that, among other
changes, will require aircraft operators to annually report the non-CO2 aviation effects of their
activities starting from January 1st, 2025. In support of this, the European Commission released
a monitoring, reporting, and verification (MRV) framework for public consultation on 1 July 2024.
The ICCT commends the Commission on proactively fulfilling this mandate. This letter offers our
perspective on the Commission’s proposal based on ICCT internal and peer-reviewed research.
Our comments on last December’s consultation, notably what data should be collected under
the system to improve the calculation of the non-CO2 impacts, can be found here. This letter
focuses on four new facets of the new proposal, namely the geographic scope, the Non-CO2
Aviation Effects Tracking System (NEATS), the default values, and the uncertainty quantification
proposed under the new regulation.
On geographic scope, we are concerned about the proposed approach to delay data collection
from extra-EU flights until 2027. The original directive specifies that the MRV must be full scope
(all flights entering or departing EEA countries). The proposed reduced scope for 2025 and
2026 would only require reporting for intra-EEA flights and flights departing from the EEA to the
UK and Switzerland. This reduced scope limits the effectiveness of the MRV in key aspects:
1. Most of the climate impact covered by the full scope is missed with the reduced
scope reporting. The climate impacts of both contrails and cruise nitrogen oxides
(NOx), are correlated to the flight distance.1 The reduced scope would only include
flights of up to 5000 km in length. Based on a 2019 inventory of contrail warming, 2 the
reduced scope would omit 30% of the flights responsible for roughly two-thirds of the
1 Dahlmann, K., V. Grewe, S. Matthes, and H. Yamashita. “Climate Assessment of Single Flights:
Deduction of Route Specific Equivalent CO2 Emissions.” International Journal of Sustainable
Transportation 17, no. 1 (January 3, 2023): 29–40. https://doi.org/10.1080/15568318.2021.1979136.
2 Teoh, Roger, Zebediah Engberg, Ulrich Schumann, Christiane Voigt, Marc Shapiro, Susanne Rohs, and
Marc E. J. Stettler. “Global Aviation Contrail Climate Effects from 2019 to 2021.” Atmospheric Chemistry
and Physics 24, no. 10 (May 27, 2024): 6071–93. https://doi.org/10.5194/acp-24-6071-2024.
total warming impact from contrails.3 It would also miss 56% of the worst warming flights
where the worst warming flights are defined as those 5% of flights responsible for 80%
of the total warming.
2. Lack of geographic coverage: Contrail formation is a highly localized phenomenon
that depends on the local weather conditions in the flight path.4 The warming impact of
NOx emissions depends on the emission altitude and background methane and NOx
concentrations.5 The flights required to report under the reduced scope would be mostly
limited to European airspace. Large geographical areas, where the impacts would be
different from those over European airspace, such as the North Atlantic, would be
missed.6 Figure 1 compares the flight routes that would be covered in the reduced
scope (blue lines) against the routes that would be missed relative to the full scope
reporting in the directive (yellow lines).
Covered in the
reduced scope
Missed in the
reduced scope
Figure 1: Geographical limits of the reduced scope reporting proposed in the implementing act.7
3 The exact percentage of warming that is missed is dependent on the weather conditions and flight
operations for that year. Based on the 2019 contrail inventory by Teoh et al., roughly 66% of the warming
impact would be missed with the reduced scope relative to full scope reporting. If that inventory is scaled
to 2023 operations, based on origin-destination pairs, the share of warming missed would be 61%.
4 Kärcher, Bernd. “Formation and Radiative Forcing of Contrail Cirrus.” Nature Communications 9, no. 1
(May 8, 2018): 1824. https://doi.org/10.1038/s41467-018-04068-0.

5 Terrenoire, E., Hauglustaine, D. A., Cohen, Y., Cozic, A., Valorso, R., Lefèvre, F., & Matthes, S. (2022).
Impact of present and future aircraft NOx and aerosol emissions on atmospheric composition and
associated direct radiative forcing of climate. Atmospheric Chemistry and Physics, 22(18), 11987–12023.
https://doi.org/10.5194/acp-22-11987-2022
6 Teoh, Roger, Ulrich Schumann, Edward Gryspeerdt, Marc Shapiro, Jarlath Molloy, George Koudis,
Christiane Voigt, and Marc E. J. Stettler. “Aviation Contrail Climate Effects in the North Atlantic from 2016
to 2021.” Atmospheric Chemistry and Physics 22, no. 16 (August 29, 2022): 10919–35.
https://doi.org/10.5194/acp-22-10919-2022.
7 The lines do not represent actual flight paths and instead represent the great circle distance between
origin and destination airports according to 2023 flight schedule data.

3. It would severely limit the review of the MRV planned for in 2027. The Commission
has been directed to submit a report by 1 January 2028 that reviews the results of the
framework in advance of a revision of the EU ETS. Due to the annual nature of
reporting, there would be no non-CO2 impact values for extra-EU flights available by the
time this report is written. This will deprive the EU of key data needed for the ETS
review, including long-haul and transoceanic flights, including in key climate sensitive
areas like the North Atlantic. With a reduced scope for 2025 and 2026, the Commission
would have no information about the worst offending flights when considering the
revision to EU ETS. This would handicap the review process and should be understood
as a delay of action, not facilitating the start of a meaningful system.
We recommend that the Commission retain the full geographic scope specified in the directive
from 2025 onwards with provisions to exclude incoming flights from countries that implement
equivalent MRV measures. This would serve as an incentive for other countries to implement
similar MRV measures. In the case that all extra-EEA countries implement equivalent
measures, the non-CO2 MRV would collect data for all flights departing EEA airports and would
capture roughly 62% of the contrail warming of the full scope and cover the same geographic
extents as the full scope.8
On the Non-CO2 Aviation Effects Tracking System (NEATS), we commend the Commission
on adopting the weather-dependent Method C as the required methodology for all except small
emitters. As mentioned previously, the non-CO2 warming impacts of aviation are highly weather-
and location-dependent and Method C should capture adequately granular data for the
estimation of the warming impact. The choice of default values to incentivize participation from
operators is also commended. However, since the impact estimation in NEATS can be
automated with the use of default values, NEATS should be used to automatically report the
impact of extra-EEA flights, which are currently being omitted for 2025 and 2026. Since NEATS
eliminates the administrative burden on airlines to report their impacts, there is no reason to
delay impact estimation on extra-EU flights to “facilitate the start of the MRV”. It is recognized
that without active participation of operators of extra-EU flights, the estimated impact would not
be as accurate as with intra-EU flights where operators are required to report data. However,
estimating the impact based on limited data is more informative than not recording any impact.
On the default values used for automatic calculation, the use of conservative values that would
systematically overpredict non-CO2 impact in an effort to incentivize data collection and
reporting by operators is understandable. The load factor of 100% in the absence of data is
justified as some airlines, such as Ryanair, have reported >95% load factor for pre-pandemic
operations.9 However, the default value used for the aromatic content may be too high. Based
on the International Civil Aviation Organization (ICAO) Engine Emissions Databank (EEDB),
which reports the minimum and maximum aromatic content of the fuel used in engine
certification tests, the aromatic content of fuels used for tests of in-service engines ranges from
11.9% to 22.5% with an average of 16.9%. Reported average values of aromatic content of jet
8 For an analysis of how regulation of international aviation emissions by country of departure can support
climate ambition, differentiation, and fair competition amongst carriers, see Kumar, Supraja, and Daniel
Rutherford. “Regulating International Aviation Emissions without Market Distortion.” Washington, D.C.:
International Council on Clean Transportation, December 21, 2023.
https://theicct.org/publication/regulating-international-aviation-emissions-without-market-distortion-dec23/.
9 ICAO Data+, Air Carrier Traffic, 2024
fuel vary from 16% to 20%.10,11 While this is not a comprehensive analysis of the fuel available
at EEA airports, it indicates that a default value of 22.5% should be sufficiently conservative to
incentivize reporting, while being more realistic than the currently proposed value of 25%.
On uncertainty quantification, while it is good that the Global Warming Potential (GWP) metric
is being reported with three time horizons, 20, 50 and 100 years, we would recommend a more
thorough uncertainty quantification process to accompany the impact estimation. Currently, only
the best estimate for the warming impact would be reported. However, given the uncertainties of
the impact estimation process, an uncertainty quantification process which accounts for
uncertainties in, at minimum, weather conditions, aircraft performance, and fuel properties is
recommended. This can be reported alongside the best estimate as a 95% confidence interval.
The calculation of the confidence interval could also be automated in NEATS with default values
for input uncertainties that can be replaced by operators that track uncertainty in their monitoring
plans. As reporting continues for multiple years, the confidence interval would also be a
measure of how the data that is being gathered for the MRV is being used to reduce the
uncertainties in the measurement and calculation processes.
In closing, the ICCT commends the commission on undertaking the design of this MRV and
appreciates the opportunity to comment on it. We recommend keeping the original reporting
requirement of all flights arriving or departing the EEA from the beginning of the MRV in 2025
with provisions to exclude incoming flights from countries that implement equivalent reporting
mechanisms. At minimum, the climate impact of extra-EU flights should be automatically
calculated by NEATS using default values for missing data. We recommend changing the
default value for the aromatic content to be 22.5% and we also recommend including
uncertainty quantification in the MRV framework that reports a 95% confidence interval
alongside the best estimate for aviation’s non-CO2 climate impact.
We thank the opportunity to provide these initial thoughts, which we expect to refine over time
into concrete recommendations as the science progresses. Please direct any questions to Dr.
Jayant Mukhopadhaya by email (j.mukhopadhaya@theicct.org) or by phone at +1 607 229
6012.
Best regards,
Dan Rutherford, Ph.D.

Senior Director of Research, International Council on Clean Transportation
10 MathPro, Inc. “Techno-Economic Assessment of Process Routes for Naphthalenes Control in

Petroleum Jet Fuel.” Washington, D.C.: International Council on Clean Transportation, March 24, 2023.
https://theicct.org/publication/naphthalene-control-jet-fuel-mar23/.
11 Barrett, Steven, and Raymond L Speth. “Naphthalene Removal Assessment – Ascent.” Accessed July
26, 2024. https://ascent.aero/project/naphthalene-removal-assessment/.

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To: European Commission, 1049 Bruxelles/Brussel, Belgium

Date: 27 July 2024

(May 8, 2018): 1824. https://doi.org/10.1038/s41467-018-04068-0.

origin and destination airports according to 2023 flight schedule data.

Dan Rutherford, Ph.D.

10 MathPro, Inc. “Techno-Economic Assessment of Process Routes for Naphthalenes Control in

26, 2024. https://ascent.aero/project/naphthalene-removal-assessment/.

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