Why the EU MRV on Non-CO2 Emissions Should Be Voluntary

By Willie Walsh, IATA's Director General

On 5 April I wrote to the European Commission expressing concerns over the European Union’s plans to compel airlines to report their non-CO2 emissions (specifically contrails) from January 2025. On 9 July my office received a request to make the letter public under public access to information requirements. We have no issue in making our position public. In fact, we published a full report backing that position.

We do not dispute the scientific evidence that non-CO₂ emissions and particularly contrails have an impact on climate change. But there is no scientific consensus on the ability to forecast persistent contrails. To achieve that we need more data on humidity. And only then, should governments look to develop policies on contrails.

Let me also emphasize that we have no issue with volunteer reporting of non-CO2 emissions data. But we oppose mandatory and extra-territorial requirements to collect data for policy-making purposes. Why? Effective policy measures are critical to guide airlines in becoming sustainable businesses. So, if policy is going to be informed by data (which we agree with), there must be scientific agreement that we are measuring the right things in the right way. In the case of contrails, for example, some may be warming, and others may be cooling. And without humidity data, it is very difficult to predict when they will be produced. In its response, the Commission essentially argued that we know enough to move forward. But on such an important issue, putting the proverbial cart before the horse is not the way to progress.

So, what are we asking for?  In our letter, we asked for consideration on four issues:

• The participation of airlines should be voluntary because current science and the proposed reporting framework cannot result in an accurate Measurement, Reporting, and Verification (MRV) process. Airlines should be encouraged to participate in data collection in support of improved estimation of non-CO2 effects, based on their ability to provide such data regarding the parameters requested.
• The scope of the MRV must be intra-EU only, to maintain consistency with the ETS scope for aviation. Any intention of expanding the scope to extra-EU international flights would raise legal concerns regarding extraterritorial effects.
• A roadmap for clear scientific validation of any monitoring and reporting of non-CO2 effects should be developed, with the purpose to explore possible pathways to effective mitigation options, which will reduce the overall climate impact (considering both CO2 and non-CO2) from aviation emissions.
• Airlines, scientific partners, and academia should be encouraged to expand trials and studies of non-CO2 The Commission’s support in these initiatives would be important, including access to funding for the installation of humidity sensors on a sample population of aircraft, without which the accurate prediction of contrail-prone regions cannot be achieved.

Freedom of information is important. We have given the Commission the ok to make the content of our letter public. If you are interested, you can access it below. Accuracy of information is also critical, hence the concerns we expressed in this letter.

While we build the capability for accurate data collections as the foundation of effective policymaking on contrails there are many important issues on the broader decarbonization agenda that need careful attention by policymakers. Not least among these is SAF. There is indisputable data pointing everyone to the conclusion that we need better policies to incentivize SAF production.

> Read the full letter to the European Commission (pdf)