Limitations of scope for aviation activities in the EU ETS

The IA defines the problems and objectives of the proposed initiative clearly, and relies on comprehensive, and updated, sources of information. Overall, most of the objectives seem to be relevant, sufficiently measurable, and achievable, though not always specific or time-bound. The selection of policy options regarding the 2017-2020 period is not entirely convincing, especially considering that those included in the initial selection were quickly discarded. The IA assesses, with a considerable level of depth, the environmental, economic, and social impacts of the options retained. The analysis is, in general, balanced, clear and comprehensive, and is supported by two quantitative models (AERO-MS, and PRIMES) previously used by the Commission. However, the choice of these models is not entirely convincing, for reasons highlighted in this briefing. The analysis of the competitiveness of small emitters (SMEs) is sufficiently broad, and includes specific sections dealing with competition between direct city-pair routes, between one-stop services, and between tourist destinations. However, it is not always easy to read and, at least in the case when the IA describes the impact of an increase in fuel prices, is sometimes not very clear. The Commission consulted a broad range of stakeholders, whose views are described and analysed extensively. The IA seems to have addressed most of the RSB's recommendations. However, it keeps the full scope of the EU ETS as the baseline, whereas the RSB recommended the continuation of the current policy as a more realistic choice. In addition, sufficient information about EU and ICAO policies on aircraft technologies, operational measures and sustainable alternative fuels, as recommended by the RSB, still seems to be missing.