Report (en)

Reference/dossier no.: L271-0595

2 Evaluation

2.1 Overview of submitted statements

The table below provides an overview of the participants in the consultation procedure:

Invited Submitted Additional statements statements Aviation associations 10 63

Aircraft operators 30 12

Airports 80

Skyguide (ATC) 10

Other4

Total 49 79

A list of the participants in the consultation procedure is provided in Chapter 4.

2.2 Interpretation of the draft Ordinance

The majority of the participants in the consultation procedure interpret the draft of the “Ordinance on the Acquisition of Data on Tonne-Kilometres performed by Aircraft” as a preparatory groundbreaking step in the direction of the integration of Switzerland’s aviation sector into an emissions trading scheme that is linked to that of the EU. Thus in their statements of position, many of the participants focus on the overlying questions of how global CO2 emissions from international air transport should be regulated and to what extent the integration of international civil aviation into a regional emissions trading scheme would be expedient and lawful. Most of the participants are in favour of measures within the framework of a globally applicable solution and currently reject the integration of Switzerland’s aviation sector into an emissions trading scheme that is linked to that of the EU. There is a widely held view that, as a consequence of the proposed preparatory data collection and intended integration of civil aviation into the emissions trading scheme, Switzerland could be exposing itself to the risk of legal disputes and, in the same way as the EU, would have to anticipate political resistance and retaliatory measures by third countries.

The most important concerns voiced by participants in the consultation procedure are summarised below.

2.2.1 Rejection of the draft Ordinance

Twelve participants petition the Federal Council to refrain from putting the ordinance into effect. (A4A, AEA, Aerosuisse, ASDA, BAR, economiesuisse, chambers of commerce of both Basel cantons, SHA, Swiss, SGV, United Airlines, VSF)

Three participants state that the collection of tonne-kilometre data should be postponed until at least the next general assembly of the ICAO (autumn 2013).

(AACO, Air Malta, IATA)

One participant criticises the fact that, with respect to the draft Ordinance no estimate was made of the regulatory consequences and costs, and furthermore that the explanatory report does not critically examine the intended link with the EU emissions trading scheme.

(SGV)

2.2.2 Criticism of the timing of the draft Ordinance and the consultation procedure

Five participants criticise the fact that, in view of the strong resistance against the EU emissions

trading scheme, the draft Ordinance and the consultation procedure have come at a very bad time.

(Aerosuisse, chambers of commerce of both Basel cantons, IATA, SHA, VSF)