HMG DOES NOT SEE EYE-TO-EYE WITH USG ENVIRONMENTAL

UNCLAS SECTION 01 OF 02 LONDON 003141 SIPDIS SENSITIVE SIPDIS DEPT FOR IO/T AND EB/TRA AMCONSUL MONTREAL PASS TO U.S. MISSION TO ICAO FAA FOR JIM FILIPATTOS, DI REIMOLD AND CARL BURLESON E.O. 12958: N/A TAGS: EAIR ETRD SENV KGHG ECON UK SUBJECT: HMG DOES NOT SEE EYE-TO-EYE WITH USG ENVIRONMENTAL POSITIONS AT ICAO REF: A. STATE 83246 ¶B. LONDON 02589 ¶1. (U) Action Request: Post received the comments at para 2 in response to ref A, from Danny Powers, Head of the International Branch, Aviation Environment Division, UK Department for Transport. HMG requests USG support and endorsement of its position as set out in para 2. ¶2. (SBU) Begin HMG Comments: United Kingdom Response to the United States Environmental Positions for the ICAO Assembly The UK welcomes this action by the U.S. in its intention to help find a constructive way forward at the ICAO Assembly. We are also seeking to be constructive. Our comments below are given against the background that it is essential to have an approach which recognizes the scale of the challenge facing aviation and responds accordingly. The U.S. proposals are constructive, however where, in our, they view represent an incomplete solution, we are looking to work with the grain and build on those proposals to present an effective way forward. (USG Talking Point 1) The United States believes it is critical for ICAO to continue its important role and efforts in addressing aviation's environmental impacts in order to ensure the sustainable growth of aviation with all the benefits it brings to the world. (USG Talking Point 5) The United States believes it critical that ICAO should continue its leadership in fostering cost-effective solutions for use by Contracting States to address the environmental objectives they have agreed to. The United Kingdom believes it is critical for ICAO to take a strong leadership role in addressing aviation's environmental impacts. The United Kingdom considers that ICAO must provide a comprehensive vision for a sustainable aviation industry that reflects the seriousness of the environmental challenge and must promote the measures necessary to realize that vision. In order to remain at the forefront of the global debate, ICAO must ensure that international arrangements keep pace with the changing context. (USG Talking Point 2) The United States endorses a systematic and comprehensive approach to mitigating 
the impacts of aircraft engine emissions on the environment. Such an approach should include better scientific understanding, modernization of air traffic management procedures, development of new lower emissions and energy-efficient technologies for aircraft and engines, and exploration of the potential of alternative fuels. (USG Talking Point 3) The United States also believes cost-beneficial market-based measures have a role to play. The United States supports endorsement of the ICAO guidance on emissions trading, provided that incorporation of airlines of other States is done on the basis of mutual consent. That is the only acceptable manner for implementation of emissions trading for international aviation consistent with international aviation law. (USG Talking Point 6) With respect to greenhouse gas emissions, ICAO should exercise leadership through the Global Air Navigation Plan to encourage improvements in fuel efficiency around the world. The United Kingdom strongly supports a systematic and comprehensive approach to mitigating the impacts of aircraft engine emissions on the environment. However, the United Kingdom believes that such an approach should include, and recognize the benefits of, market-based measures. The United Kingdom is disappointed, therefore, that market-based measures do not form part of the United States' vision of a systematic and comprehensive approach. We are also disappointed that the United States does not appear to have accepted the conclusion reached by CAEP/7 in relation to the guidance on market based measures. The United Kingdom notes further that there have been discussions through CAEP including a meeting of legal experts. That meeting did not reach a conclusion that "mutual consent" was the only acceptable manner for implementation of emissions trading for international aviation consistent with international aviation law. Point 3 must therefore be seen as an opinion - with other states having a different opinion - rather than a statement of fact (USG Talking point 4) The United States believes the guidance developed on local air quality emissions charges is a step forward. However, we still have doubts about whether these charges are cost- effective in many cases. ICAO should further assess the cost-effectiveness of such charges. For States using such charges we encourage transparency, openness, and accountability in how such charges are set and revenues employed. The United Kingdom believes that the ICAO guidance provides an effective framework for the consideration of local air quality emissions charges. In relation to further work, the United Kingdom considers that the FESG analysis on the cost-effectiveness of local air quality charges prepared for CAEP/7 represented the result of well- considered work. CAEP accepted the conclusions drawn from the analysis. We do not therefore see a role for further assessment at this stage. But, of course, we share the desire for openness and accountability which is set out in the guidance. (USG Talking point 7) Further, development of an ICAO Emissions Plan must include a systematic understanding of trends in growth, impacts of various emissions, changes in aircraft technology, air traffic operational improvements and trade-offs between various environmental objectives - especially mitigation strategies. ICAO's Emission Plan should also reflect a philosophy that a "one size fits all" approach will not be effective in tackling the important issue of aviation greenhouse gas emissions. The United Kingdom agrees that an Emissions Plan needs to incorporate these elements, but believes that it must also set out a clear vision of how ICAO will achieve its environmental goal of limiting or reducing the impact of aviation greenhouse gas emissions on the global climate. Such a Plan also needs to provide States with sufficient flexibility to adopt appropriate measures to tackle aviation greenhouse gas emissions. The United Kingdom solicits your support and endorsement of its position as set out in this response. End HMG Comments. Visit London's Classified Website: http://www.state.sgov.gov/p/eur/london/index. cfm TUTTLE