Bellona welcomes the amendment to the Implementing Act requiring operators to monitor and report emissions from both non-zero rated and zero-rated carbon fractions as memo-items in emission reports. This step is crucial for reducing absolute CO₂ emissions and highlighting the overall carbon flow to the atmosphere. Bellona also supports the inclusion of non-CO₂ aviation effects in monitoring and reporting, particularly for alternative fuels containing zero-rated carbon fractions. These measures contribute to a more comprehensive understanding of the climate impact of all emissions, regardless of their origin.

However, Bellona calls on the European Commission to ensure that CO₂ transport for purposes other than geological storage is subject to the same monitoring, reporting, and cost obligations as CO₂ transport for geological storage. The current exemption for non-geological storage purposes creates a gap in accountability. Additionally, Bellona urges the Commission to implement monitoring schemes for all flights within the full scope of the EU ETS, including long-haul flights between the EU and non-EU countries, to capture the holistic climate impacts of aviation, including non-CO₂ effects. This comprehensive approach is essential for informed policy-making and effective climate action.

Read our full consultation response below.

• Consultation Response 29.07.2024 (pdf)