Monitoring emissions
How should CO2 emissions be calculated?
The following formula will be used to calculate the CO2 emissions:
CO2- emission = fuel consumption x emission factor
The fuel consumption (tonnes) will be determined by the company using fuel measurements in the aircraft and/or the fuel deliveries data.
The emission factor (CO2 tonnes/fuel tonnes) will be determined generically by the European Commission for the different types of standard fuels used in aviation.
The precise method for monitoring fuel consumption is laid down in the Monitoring and Reporting Guidelines (MRG) of the European Commission. In cooperation with the UK Environment Agency, NEa has designed a Guidance for the Aviation Industry. This document provides a detailed interpretation of the MRG.
Annual emissions monitoring plan
The methodology for monitoring emissions must be defined in a monitoring plan that requires the prior approval of NEa. The European Commission developed monitoring plan templates that operators are obliged to use for drafting their own monitoring plan.The directive makes it mandatory to start monitoring emissions based on an approved monitoring plan from 1 January 2010.
Simplified monitoring procedures will apply to operators with small CO2 emissions. This means non-commercial operators that operate fewer than 243 flights in each of three successive periods of four months or that emit less than 10,000 tonnes of CO2 per calendar year.
Notification of changes of the monitoring plan
Since changes of monitoring plans are likely to occur over time, monitoring plans are no static documents. It is the operator's responsibility to keep monitoring plans up-to-date. All changes of monitoring plans have to be notified to NEa. Verifiers will not approve annual emissions reports if these are based on outdated monitoring plans or monitoring plans with changes that have not been approved by NEa.
All changes should be notified in advance, using the notification form. NEa then has eight weeks to formally approve or disapprove the proposed change.
Changes that do not affect the monitoring plan need not be notified. This means that:
- Changes in fleet (addition of aircraft types) in accordance with the procedures described in the approved monitoring plan (box 4c) need not be notified;
- Modifications of underlying procedures that are referred to in the monitoring plan need not be notified, unless they result in changes in the descriptions of procedures that are included in the monitoring plan.

