Which allocation methodology should be used to maximise efficient and cost effective reductions in emissions?
Of the 51 responses, 12 had no specific preference although one stated that the chosen allocation methodology should result in the lowest level of emissions. 15 responses believed that benchmarking should be the chosen allocation methodology as it can drive efficient operations, reward early action and does not have a high financial impact on airlines. These responses argued that auctioning does not affect the amount of emissions reductions; it would simply divert financial resource away from the airline sector which would impact an operator’s cash flow and could affect competitiveness. The point was also raised that in the current phase of ETS Member States have shown little support for auctioning, and therefore questioned why it should be applied to aviation, particularly if other sectors will not be subject to the same levels of auctioning. There were 13 responses in favour of auctioning, with 6 of those coming from the NGO/charity group. Support for auctioning was on the basis that