Report (en)

Reference/dossier no.: L271-0595

flights and to submit only the data for these flights to the Swiss authorities.

(A4A, United Airlines)

2.3.2 Optional versus mandatory data collection

Three participants demand that data collection should not be declared mandatory, but rather should be optional in line with the principle that is applied in the EU emissions trading scheme (i.e. in the form of an application for allocation of emission rights free of charge in a future emissions trading scheme). (AACO, Air Malta, IATA)

2.3.3 Thresholds for operators with a low number of flights

Two participants argue that, unless a threshold is specified for operators with a low number of flights, the Ordinance will not be implementable.

(A4A, United Airlines)

One participant criticises the fact that, in the consultation documentation, no provision has been made for a de minimis threshold for commercial air operators.

(VSH)

2.3.4 Deadline for submitting monitoring plans

Five participants complain that the foreseen deadline of 30 September 2012 for submitting monitoring plans is too tight.

(A4A, AACO, Air Malta, IATA, United Airlines)

Three participants demand that, in the event of a postponement of the deadline for data collection, the deadline for submitting monitoring plans should also be postponed accordingly.

(AACO, IATA, United Airlines)

Two participants demand that the deadline for submitting monitoring plans should be postponed until 30 November 2012 at the earliest. Furthermore, if the negotiations with the EU are not concluded by 30 September 2012, the deadline must be postponed again.

(AACO, IATA)

Two participants demand that, for submitting monitoring plans, aircraft operators should be granted a deadline of at least 120 days from the date of entry into force of the Ordinance.

(A4A, United Airlines)

2.3.5 Scope of application for data collection

One participant states that flights with helicopters with a take-off weight of more than 5,700 kg should also be exempted from the data collection requirement, since the process of collecting data would be entirely disproportional to the volume of collected data.

(SHA)

2.3.6 Confidentiality of data

Two participants demand that the confidential treatment and archiving of data must also be

guaranteed in the event that data are forwarded to other parties.

(A4A, United Airlines)

2.3.7 Criteria for the verification of monitoring reports

One participant draws attention to the fact that some of the criteria for the verification of monitoring reports are not clear and should be adapted to the requirements specified in the EU emissions trading scheme.

(PWC)