Commencing January 1st, 2025, aircraft operators under the purview of the EU ETS will have the added responsibility of monitoring and reporting their non-CO2 effects, which encompass soot particles, water vapour, nitrous oxides (NOx) and oxidised sulphur species. The monitoring and reporting requirements of non-CO2 aviation effects are currently being developed by the European Commission and are set to be published in the MRR in early September 2024.
It is important to note that, until at least 2028, there is no requirement to surrender EU ETS allowances for the reported non-CO2 effects. A thorough review will be conducted at that juncture to reassess the situation by the European Commission.
Scope
As established in the ETS Directive, the monitoring and reporting of non-CO2 effects is mandatory for intra- and extra-European Economic Area (EEA) flights. However, to help facilitate the start of the monitoring and reporting on non-CO2 aviation effects, the European Commission has decided to implement a temporary derogation in the scope. For the initial two years (2025 and 2026) of the monitoring and reporting obligation, a reduced scope will apply. The scope is limited to include intra-EEA flights and flights from the EEA to Switzerland (CH) and the United Kingdom (UK). Voluntary reporting of flights outside the reduced scope is possible.
Monitoring methods and monitoring plan
The European Commission has developed two monitoring methods for the monitoring of non-CO2 aviation effects, Method C and Method D. Method C is the standard method consisting of a weather-based approach, using primarily enhanced weather data, as well as flight information, trajectory data, aircraft properties and fuel properties. Method D is a simplified monitoring method and consists of a location-simplified approach that may be used by small emitters (as defined in Article 55(1) of the MRR). Method D uses primarily aircraft in-flight location-related data such as flight information, trajectory data, but also basic weather data and aircraft properties.
According to the draft MRR, the official deadline for submitting your non-CO2 monitoring plans is set for September 1, 2024. However, given that the revised MRR is expected to be published on in September 2024, and the new monitoring plan template is anticipated in Q4 2024, this deadline is not viable. Once the new monitoring plan templates have been published, we will provide further details regarding the deadline for submittal.
NEATS tool
The European Commission is launching a new IT tool called the Non-CO2 Aviation Effects Tracking System (NEATS) to automatise the monitoring and reporting process. This tool aims to simplify the process for aircraft operators, requiring them only to input basic aircraft properties (such as type, engine identifier, and mass) and fuel properties. In case where no data is provided, default values will be used, offering the possibility of a fully automatic monitoring, reporting and verification process.
NEATS automatically gathers and integrates most other necessary data, including flight information, trajectory details, and weather conditions. The collected data is then utilized in an emission module to initially compute emissions per flight. Subsequently, using open-source models, NEATS calculates the CO2 equivalent of these emissions for multiple time horizons (20, 50, and 100 years) based on the Global Warming Potential (GWP) metric. At the end of the reporting year NEATS will generate a report, which needs to be submitted to the competent authority.
Aircraft operators are required to report the non-CO2 effects of their flights for the first time by March 31, 2026.
Training sessions and guidance
The European Commission plans to provide training sessions for aircraft operators on the monitoring and reporting of non-CO2 effects and the NEATS tool this autumn. Keep an eye out for information on this.
Lastly, a step-by-step guide established by the European Commission with further explanations for aircraft operators on the monitoring and reporting of non-CO2 effects of aviation is available here: Explainer non-CO2 MRV tasks for AO_June2024 | Guideline | Dutch Emissions Authority.