The document is Carbon Market Watch’s response to a stakeholder survey organised in the context of the drafting of a study by the European Commission’s DG MOVE on the subject of carbon leakage and mitigating measures in the EU aviation sector.

The consortium responsible for the survey and drafting of the study is led by consultancy TIS Portugal, in partnership with Panteia, Oeko-Institut and Würzburg University.

In its answer, Carbon Market Watch makes clear that no carbon leakage risk has been observed for EU aviation until now and that the potential future carbon leakage which could result from the implementation of more ambitious policies (eg EU ETS coverage of all departing flights) would likely be very limited and would not justify any decrease in climate ambition.

If effectively observed, the EU could make up for the limited potential carbon leakage with tailored measures. Beyond providing evidence about the observation or not of carbon leakage, we comment on the proposed measures.