Swiss Aviation Emissions Trading Deadline Imminent

Aircraft operators flying into and out of Switzerland from the EU and domestically in Switzerland are required to deliver the first data for the country’s new emissions trading scheme (ETS) by the end of this month. With the deadline fast approaching, many business aviation operators might not be aware that the new scheme came into force on July 1, with data acquisition taking place from Jan. 1 to Dec. 31, 2018. It is being administered by the Swiss Federal Office for the Environment (FOEN).

Switzerland and the EU are seeking to link their respective emissions trading systems, but until an agreement is reached and enters into force, the two systems will run in parallel. This means operators will have to deal with two “competent authorities”—the Swiss FOEN and their current competent authority for EUETS.

Participating operators must submit metric ton-kilometer monitoring plans to FOEN by September 30; monitor distance and payload information for qualifying flights in 2018 in accordance with the approved monitoring plan and the “Swiss Ordinance” directive; and submit a verified monitoring report for 2018 to FOEN by March 31, 2019.

The metric ton-kilometer data collected will serve as a basis for the allocation of free emission allowances and will also be used to determine the system-wide emissions cap. Operators failing to submit a plan may face a fixed penalty of up to 5,000 Swiss francs ($5,000), according to FOEN.

Flights to and from points outside the EU are not included in the EUETS or new Swiss ETS—the former because of the “stop the clock” provisions that have now been extended to coincide with the introduction of the ICAO’s international CORSIA scheme in 2020.

According to FOEN guidance material, operators need to ask themselves, “Did my flight department participate in EUETS in 2016?” Participation means the act of reporting CO2 emissions from 2016 and the surrendering of emissions allowances.

If yes, then the operator must submit a metric ton-kilometer monitoring plan, “Unless you know already that you will not carry out qualifying flights in 2018.” Even if they submit a plan, operators are still exempt from submitting verified metric ton-kilometer reports for 2018 if they have no qualifying flights in the year.

If the answer to the above question is no, operators are required to submit a monitoring plan “only If you were above the Swiss de minimis threshold in 2016.”

A commercial operator is below the de minimis threshold if it operates less than 243 qualifying flights in each of the three successive four-month periods, or if its total annual emissions of CO2 from all qualifying flights are below 10,000 metric tons.

A private, non-commercial operator is below the de minimis threshold if its total annual emissions of CO2 from all qualifying flights is below 1,000 stonnemetric tons. As with EU ETS, the Swiss ETS also exempts flights performed by aircraft with a MTOW of less than 5,700 kg/12,566 pounds, circular flights or training flights (these being the main exemptions).

Qualifying flights that operators must keep track of, broadly speaking, are domestic flights in Switzerland or flights from Switzerland to member states of the European Economic Area (EEA). Metric ton-kilometer monitoring plans can be created using a template provided by FOEN and then e-mailed with a paper copy being lodged with FOEN itself marked “Monitoring Plan Aviation Operators.”

AIN asked Tobias Konik, chief executive of Swiss company First Choice Carbon (FCC Aviation), why Switzerland didn’t wait for ICAO‘s CORSIA system to come into effect in 2020. “It would make sense to wait for CORSIA. I guess the main reason is that Switzerland and the EU started the negotiations a long time ago. This was even before CORSIA. And now they want to finish off what they have started,” said Konik.

In addition, it is my understanding that, at least, Swiss domestic flights would be outside of the scope of CORSIA. With Swiss ETS, they have these flights covered.”

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