blue skies project ISTOCK PHOTO Is t he Sky F alling for Airline Profits in the European Union? The Consequences or Airlines rom the Inclusion oAviation in the EU Emissions T rading System By Samuel Grausz and Nigel Purvis with Rebecca Leton February 2012
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Is the Sky Falling for Airline Profits in the European Union?
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Furher, inernaional aviaion emissions are specically excluded rom he Kyoo
Proocol, which direcs governmens o work hrough he Inernaional Civil
Aviaion Organizaion, or ICAO, o develop a global mechanism o reduce avia-
ion emissions. Te European Union decided o move ahead o he ongoing ICAO
process as i el ha process was proceeding oo slowly.
Te EU aviaion policy isel is as ollows: Saring in 2012 airlines will be required o
obain permis, also known as “allowances,” or each on o emissions produced by all
o heir ighs deparing rom or arriving in he European Union and oher parici-
paing saes.4 Te allowances are no like radiional air polluion permis, speciy-
ing complicaed limiaions and exac acions ha he polluing eniy mus ollow.
Insead hey are more like a orm o currency, eniling he eniy o emi one meric
on o CO2. Mos conroversially he policy includes all airlines, no jus EU airlines,
and all emissions hroughou he enire igh pah, including ouside he EU airspace.
Covered airlines can acquire allowances hrough a number o sources. Te larg-es source will be he allowances issued o he airlines or ree by he European
Union, which will add up o 85 percen o all he allowances he European Union
will creae or airlines.5 Te ree allowances are divided beween airlines based on
each airline’s share o pas operaions.6 Airlines can also “borrow” allowances rom
uure years o mee obligaions in a given year.
Ouside o ree allowances airlines can purchase he allowances hrough ofcial
EU allowance aucions. Tese aucions will sell o he remaining 15 percen
o he allowances creaed by he European Union. Furher, airlines can buy he
allowances rom oher airlines or companies in oher secors covered by he EU
Emissions rading Sysem such as elecriciy generaors and many indusries in
he European Union. Tis is he “rade” par o “cap and rade.”
Finally, airlines can obain allowances by paricipaing in he Kyoo Proocol’s Clean
Developmen Mechanism, which allows regulaed eniies o obain allowances by
demonsraing hey have helped reduce emissions in developing counries. Once
hey acquire hese allowances, airlines can choose o use he allowances o mee heir
obligaions in he curren year or o hold he allowances o mee heir obligaions
in uure years, a pracice known as “banking” in cap-and-rade circles. Te policy reduces oal CO2 emissions by only issuing enough allowances o cover a porion o
airline emissions. Tis upper limi on oal emissions is known as he “cap.” Te cap
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maes he change in revenue resuling rom he change in icke price. Tis sudy
nds ha an increase in average icke prices o beween $8.90 and $19.00—near
he mean o esimaes by oher sudies—causes an increase in revenue o beween
$4.2 billion and $8.9 billion. Exrapolaing rom his sudy and he changes in
icke prices esimaed by oher sudies shows ha he $0.53 o $39 increase in
icke prices ound or all sudies resuls in an increase in revenue o beween $248million and $18 billion.
Te icke price changes described above require some explanaion. Firs, no all
sudies ha esimae emissions coss also calculae changes in icke prices and
vice versa. As a resul he range o emissions coss is no direcly comparable o
he range o icke price changes. Looking only a he wo sudies ha esimae
boh emissions coss and changes in icke prices, he range or emissions coss is
beween $2.40 and $25.30 per passenger, and he range in changes in icke prices
is beween $2.40 and $19.
Second, dieren sudies assume very dieren raes a which airlines will pass
hrough coss o consumers. Te sudy by Erns & Young (2007) assumes a pass-
hrough rae o 29 percen o 35 percen, depending on he ype o airline and he
year, while IAA (2007) assumes a pass-hrough rae o 75 percen, and Boon e
al. (2007) assumes a pass-hrough rae o 100 percen.
Te exen o which airlines pass hrough o consumers heir emissions coss depend
on a number o acors on boh he supply and demand side.17 Mos sudies consider
a subse o hese issues when deermining pass-hrough raes. A mos hey discuss
wo key parameers: he elasiciies o demand and supply. Tese reer o he aggre-
gae willingness o consumers o coninue o purchase ickes despie acing higher
coss and he willingness o airlines o oer ighs a lower prices. Our sudy does
no atemp o delve ino hese elasiciies or he resuling pass-hrough raes.
Changes in demand
Te changes in icke prices in urn could drive a reducion in demand or airline
ickes. Te poenial reducion in demand is deermined by he size o he change inicke prices and he elasiciy o demand or airline ravel, wih a more elasic demand
causing a larger decrease in icke prices. As exising sudies ound small changes in
icke prices, i is unsurprising ha hey also showed small changes in demand. Only
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Beore diving ino a discussion o subgroups and eecs on compeiiveness, i is
imporan o describe exacly wha we mean by compeiiveness and in wha sense
i maters o airlines. A good working deniion o he eecs o a policy on com-
peiiveness could be he exen o which i helps or hurs one airline more han
anoher. In general each airline seeks o maximize is own pros, so compeiive-
ness really reers o he relaive eec o he policy on each airline’s pros.
Tere are wo primary pro impacs ha are likely o dier beween airlines. Firs,
airlines receive dieren amouns o ree allocaion depending on heir hisorical
emissions. I an airline receives relaively more allocaion han anoher, he airline
can be said o gain a compeiive advanage. Tis ype o compeiive advanage,
however, does no necessarily resul in he advanaged airlines aking any marke
share rom he disadvanaged airline.
Second, he changes in icke prices caused by he program have a complex eec
on coss, revenues, and pros. As described in deail in he previous secion, heprice on carbon will raise icke prices, causing consumers o buy ewer airline
ickes. Te exen o which each airline increases is prices and each passenger
reduces or shis is demand depends on a number o acors, which inerac in
complex ways. Te acors include he efciency o he airline’s curren ees,
he abiliy o he airlines o reduce emissions cheaply, he compeiiveness o he
markes he airlines operae in, he characerisics o he passengers wihin each
marke, and he responsiveness o he passengers wihin each marke o changes in
icke price.21
None o he sudies we examined provided resuls a a level o deail o deermine
he causes o dieren changes in pros. Very ew o he sudies, in ac, even cal-
culaed changes in pros or subgroups. Careully dening compeiiveness and
he mechanisms or dierences in los pros will help by enabling us o heorize
why sudies ound dieren changes in pros or dieren subgroups and o draw
some conclusions rom he available resuls.
As we show in he nex secion, we expec EU airlines as a whole o gain signi-
canly more pros han non-EU airlines as a resul o he policy. Tis is largely
because EU airlines have hisorically had a larger volume o operaions covered by he policy, no because he EU policy is inherenly discriminaory. In ac he EU
aviaion policy reas all airlines equally by requiring each airline, regardless o is
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wo oher sudies (Schaeer e al., 2010; IAA, 2007) nd ha EU airlines will
ace signicanly more ou-o-pocke coss han non-EU airlines. As discussed in
he secion on overall resuls, he relaive ou-o-pocke coss say very litle abou
he relaive eec on pros. Te resuls rom all o hese sudies are shown in
able 2 as well as he ables in Appendix B.
As discussed above, hese resuls do no necessarily imply ha he EU aviaion policy
is discriminaory. Te policy reas all airlines he same by requiring each airline o
urn in one allowance or each meric on o emissions and by providing he same ree
allocaion or each on o hisorical emissions. Te remaining dierences in eecs on
pros are he resul o economic acors beyond he conrol o he policymakers.
TABLE 2
Policy impacts by airline nationality
Category Units EU airlines US airlines Non-EU airlines
Out-o-pocket costs
Total
Schaeer et al 2010 Million USD $1,270 to $2,032 $258 to $413
IATA 2007 Million USD $1,095 to $2,124 $172 to $334 $322 to $625
Change in profts
Total
Boon et al (Delt) 2007 Million USD NA to $9,216 NA to $5,532
Malina et al (MIT ) 2012 Million USD $116
Margin
Boon et al (Delt) 2007 Percent NA to 2.30 NA to 0.60
Malina et al (MIT) 2012 Percent 0.15
Airline types
Te airlines hemselves are probably mos concerned abou he relaive eecs o he
EU aviaion policy on hem and heir compeiors. Alhough radiional nework
airlines compee regularly agains each oher, hey also increasingly compee agains
low-cos airlines or shor- and medium-disance ighs. Tis compeiion is par-icularly erce in Europe, wih he rise o low-cos airlines such as RyanAir, easyJe,
and many ohers. Faced wih his increased compeiion, boh nework and low-cos
airlines are likely very concerned wih he relaive eecs o he EU aviaion policy.
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Abrell, Jan. 2011. “Privae ranspor and he European
Emission rading Sysem: Revenue Recycling, Publicranspor Subsidies, and Congesion Eecs.” SocialScience Research Nework eLibrary, available ahtp://papers.ssrn.com/sol3/papers.cm?absrac_id=1844300.
Anger, Annela. 2010. “Including aviaion in he Europeanemissions rading scheme: Impacs on he indusry,CO2 emissions and macroeconomic aciviy in he EU.” Journal o Air ranspor Managemen 16 (2): 100–105.
Anger, Annela, and ohers. 2008. “Air ranspor inhe European Union Emissions rading Scheme.”
Anger, Annela, and Jonahan Köhler. 2010. “Includingaviaion emissions in he EU ES: Much ado abounohing? A review.” ranspor Policy 17 (1): 38–46.
Bloomberg. 2011. “Including Aviaion in he EU ES - TeBurning Quesion.” Bloomberg New Energy Finance,available a htp://bne.com/ree-publicaions/whie-papers/.
Boon, Bar, and ohers. 2007. “Allocaion o Allowances
or Aviaion in he EU ES.” Te Neherlands: CE Del,available a htp://www.cedel.eu/publicaie/alloca-ion_o_allowances_or_aviaion_in_he_eu_es/575?PHPSESSID=ad8353cb75ccd097561c2c46a66a.
Cames, Marin, Odete Deuber, and Ulrike Rah. 2004.“Emissions rading in Inernaional Civil Aviaion.” Ber-lin: Insiue or Applied Ecology, available a htp:// www.umweldaen.de/publikaionen/pd-l/2605.pd.
Dorbian, Chrisopher S., Philip J. Wole, and Ian A. Waiz.2011. “Esimaing he climae and air qualiy benes o aviaion uel and emissions reducions.” Amospheric
Environmen 45 (16): 2750–2759.
Erns & Young. 2007. “Analysis o he EC Proposal o
Include Aviaion Aciviies in he Emissions rad-ing Sysem.” Washingon: Erns & Young, available ahtp://www.obsa.org/Liss/Documenacion/Atach-mens/124/Analysis_EC_proposal_include_avia-ion_ES_EN.pd.
Erns & Young. 2008. “Inclusion o Aviaion in he EUES: Cases or Carbon Leakage.” Washingon: Erns& Young, available a htp://www.iaca.be/index.cm?AFF5184E-BDBE-2776-0CC0-9E3D55BCA9FB.
European Commission. 2011. “Reducing Emissions romhe Aviaion Secor”. Brussels, Belgium: European
Commission, available a htp://ec.europa.eu/clima/policies/ranspor/aviaion/index_en.hm.
Faber, Jasper, and Linda Brinke. 2011. “Te Inclusiono Aviaion in he EU Emissions rading Sysem.”Geneva, Swizerland: ICSD Programme on radeand Environmen, available a htp://icsd.org/down-loads/2011/09/aber_web2gp2.pd.
Fronier Economics. 2006. “Economic Consideraion o Exending he EU ES o Include Aviaion.” London,available a htp://www.elaa.com/documens/Froni-erEconomicsrepororELFAA-Economicconsideraion.
pd.
Heymann, Eric, and Joachim Harel. 2011. “Emissionsrading in aviaion.” Frankur: Deusche Bank Research,available a htp://www.dbresearch.de/PROD/DBR_INERNE_DE-PROD/PROD0000000000280535/Emissions+rading+in+aviaion%3A+Moderae+burdens+or+he+ime+being,+percepible+compeiion+eecs.pd.
Hihara, Kasuya. 2011. “Analysis on bargaining abouglobal climae change miigaion in inernaional avia-ion secor” ransporaion Research Par E: Logisics
and ransporaion Review 47 (3): 342–358.
IAA. 2007. “Financial Impacs o Exending he EU ESo Airlines.” Geneva: Inernaional Air ranspor As-sociaion.
Appendix A
Reerences
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IAA. 2011. “Financial Forecas.” Geneva: Inernaional Air ranspor Associaion, available a htp://www.iaa.org/whawedo/Documens/economics/Indusry-Oulook-Sepember2011.pd.
ICF Consuling. 2006. “Including Aviaion ino he EUES: Impac on EU Allowance Prices.” London, avail-able a htp://www.decc.gov.uk/asses/decc/wha%20
Knigh, Zoe, Celine Fernaro, and Samanha Gleave. 2008.“Aviaion in EU ES; an incenive or edfciency.”Merrill Lynch, available a htp://www.ml.com/me-dia/113530.pd.
Macinosh, Andrew, and Lailey Wallace. 2009. “Inerna-ional aviaion emissions o 2025: Can emissions besabilised wihou resricing demand?” Energy Policy 37 (1): 264–273.
Malavoli, Eselle, and Julien Jenvrin. 2010. “SraegicReacion o Airlines o he ES,” available a htp://inrane.ime.gr/Porals/0/UseulDocumens/docu-mens/01654.pd.
Malina, Rober, and ohers. 2012. “Te impac o he Eu-ropean Union Emissions rading Scheme on US avia-ion.” Journal o Air ranspor Managemen 19: 36–41.
Mayor, Karen, and Richard S. J. ol. 2007. “Te Impac O Te Uk Aviaion ax On Carbon Dioxide Emissions And Visior Numbers.” Working Papers. Hamburg, Ger-
many: Research uni Susainabiliy and Global Change,available a htp://ideas.repec.org/p/sgc/wpaper/131.hml.
Mayor, Karen, and Richard S.J. ol. 2010. “Te impac o European climae change regulaions on inernaionalouris markes.” ransporaion Research Par D:ranspor and Environmen 15 (1): 26–36.
Mendes, Lucas M Z, and Georgina Sanos. 2008. “Usingeconomic insrumens o address emissions rom airranspor in he European Union.” Environmen andPlanning A 40 (1): 189–209.
Morrell, Peer. 2007. “An evaluaion o possible EU airranspor emissions rading scheme allocaion meh-ods.” Energy Policy 35 (11): 5562–5570.
Morrell, Peer. 2010. “Te Economics o Co2 Emis-sions rading or Aviaion.” Te Fuure or InerurbanPassenger ranspor, 459–481, available a htp:// www.oecd-ilibrary.org/ranspor/he-uure-or-inerurban-passenger-ranspor/he-economics-o-co2-emissions-rading-or-aviaion_9789282102688-18-en;jsessionid=52d4gbbolqab.epsilon?cieorma=ris.
OAG. 2012. “EU Emissions rading Scheme Repor.”OAG Marke Inelligence, available a htp://www.oagaviaion.com/Soluions/Repors-Guides/ES/ES?um_source=pressrelease&um_medium=ubmaviaion&um_campaign=es.
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Schaeer, Marin, and ohers. 2010. “Te economic impaco he upcoming EU emissions rading sysem on air-lines and EU Member Saes—an empirical esimaion.”European ranspor Research Review 2: 189–200.
Scheelhaase, Janina D., and Wolgang G. Grimme. 2007.“Emissions rading or inernaional aviaion—an esi-maion o he economic impac on seleced Europeanairlines.” Journal o Air ranspor Managemen 13 (5):253–263.
Scheelhaase, Janina, Wolgang Grimme, and Marin
Schaeer. 2010. “Te inclusion o aviaion ino he EUemission rading scheme – Impacs on compeiion beween European and non-European nework airlines.”ransporaion Research Par D: ranspor and Envi-ronmen 15 (1): 14–25.
SEC. 2006. “Impac Assessmen o he Inclusion o Aviaion Aciviies in he Scheme or Greenhouse GasEmission Allowance rading wihin he Communiy.”Brussels: Commission o he European Communiies.
ol, Richard S. J. 2006. Te Impac o a Carbon ax onInernaional ourism. Dublin, Ireland: Economic and
Social Research Insiue (ESRI). htp://ideas.repec.org/p/esr/wpaper/wp177.hml.
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Vespermann, Jan, and Andreas Wald. 2011. “Much Adoabou Nohing? – An analysis o economic impacs andecologic eecs o he EU-emission rading scheme inhe aviaion indusry.” ransporaion Research Par A:Policy and Pracice 45: 1066–1076.
Vivid Economics. 2007. “A Sudy o Esimae icke PriceChanges or Aviaion in he EU Emission rading
Scheme.” London. Available a htp://www.vivideco-nomics.com/index.php/publicaions/a-sudy-o-esi-mae-icke-price-changes-or-aviaion-in-he-eu-es.
Vivid Economics. 2008. “Impacs o Emissions rading onPros in Aviaion”. London. Available a htp://www. vivideconomics.com/index.php/publicaions/impacs-o-emissions-rading-on-pros-in-aviaion.
Wi, Ron, and ohers. 2005. Giving Wings o Emissionrading. Te Neherlands: CE Del, available a htp://ec.europa.eu/clima/policies/ranspor/aviaion/docs/
aviaion_e_sudy_en.pd.
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1 International Civil Aviation Organization. “ICAOEnvironmental Report 2010” (2010), available at http://www.icao.int/environmental-protection/Pages/EnvRe-port10.aspx.
2 Artur Runge-Metzger, “Aviation and Emissions Trading:ICAO Council Brieng,” September 29, 2010, available athttp://ec.europa.eu/clima/policies/transport/aviation/docs/presentation_icao_en.pd . Percent change rela-tive to a 2006 baseline.
3 International Civil Aviation Organization. “ICAO Envi-ronmental Report 20 10.”
4 Other participating states include Iceland, Lichtenstein,and Norway. Croatia, when it joins the European Unionin 2013, will become part o the program. The policydoes not include ights with a minimum take-of weight less than 5,700 kg, training and military ights,and ights to remote regions. For more, see: EuropeanCommission, “Reducing Emissions rom the AviationSector” (Brussels: European Commission, 2011), avail-able at http://ec.europa.eu/clima/policies/transport/aviation/index_en.htm.
5 In 2020, 85 percent o the allowances will be issued orree to existing airlines. Each year rom 2013 to 2020,82 percent o the allowances will be issued or ree toexisting airlines and 3 percent will be kept in reserve orast-growing and new airlines.
6 Measured in tonne-kilometers in passengers andreight in 2010.
7 The European Union will create enough new allow-ances to cover 97 percent o average aviation emissionsrom 2004 to 2006 in 2012, and 95 percent in 2013 andthereater.
8 Most importantly, we do not compare allowance priceassumptions. These assumptions, more than anythingelse, are likely drive the variety o results.
9 This importantly leaves out a number o studies thatestimate impacts on the European or global economy
and studies that estimate impacts on specic airlinesor specic ight patterns. In a ew cases, we did includeestimates or specic airlines when the results or thoseairlines are intended to represent an airline subgroup.
10 The value o the allowances is not actored into thechanges in ticket prices and demand and is included as asource o prots because the EU policy allocates ree al-lowances based on historical emissions. Economic theorysuggests that this will occur because ree allowancesbased on historical emissions do not afect the marginalcost o emissions and thus airlines will not pass throughthe value o the allowances to consumers and will insteadkeep the ree allocation as prot. Economists havedocumented this efect empirically in a large number o studies. For good examples, see: Jos Sijm, S Hers, W Lise,and B Wetzelaer, “The impact o the EU ETS on electricityprices,” Environmental Protection (2008); Jos Sijm, KarstenNeuhof, and Yihsu Chen, “CO2 cost pass-through and
windall prots in the power sector,” Climate Policy 6(1) (2006): 49–72; Lans A. Bovenberg, and Lawrence H.Goulder, “Neutralizing the Adverse Industry Impacts o CO2 Abatement Policies: What Does it Cost?” NBER Work-ing Papers, available at http://ideas.repec.org/p/nbr/nberwo/7654.html; Dallas Burtraw and Karen Palmer,“Compensation rules or climate policy in the electricitysector,” Journal o Policy Analysis and Management 27 (4)(2008): 819–847.
11 No study estimates and presents total costs or allcovered airlines. We approximate total covered costsas the costs or all European air travel, calculated usingworldwide aviation costs and regional market sharesrom IATA. This approximation may be inaccurate tothe extent that the costs o airlines difer betweenregions and to the extent that the IATA Europe regiondoes not line up with the coverage o the EU policy.See: IATA, “Financial Forecast” (Geneva: International Air
Transport Association, 2011), available at http://www.iata.org/whatwedo/Documents/economics/Industry-Outlook-September2011.pd; IATA, “Air Transport MarketAnalysis” (Geneva: International Air Transport Associa-tion, 2011), available at http://www.iata.org/whatwedo/Documents/economics/MIS_Note_Sep11.pd.
12 Similar to above, we approximate total uel costs orcovered airlines using the uel costs or all Europeanair travel, calculated using worldwide aviation costsand regional market shares rom IATA. We use regionalmarket shares or 2010 in all years, as IATA only makesdata publicly available or that year.
13 European Commission, “Reducing Emissions romthe Aviation Sector” (Brussels: European Commission,2011), available at http://ec.europa.eu/clima/policies/transport/aviation/index_en.htm.
14 IATA (2007) does not explicitly show these numbersbut they do provide ull costs per passenger and totalnumber o passengers.
15 The diference between the out-o-pocket and emis-sion cost or IATA (2007) does not exactly match thevalue o ree allocation calculated in the previousparagraph because IATA (2007) assumes a 10% auctionrate rather than the 15% auction rate included in thenal policy. We corrected or this in the extrapolationo the other studies. Also, we chose to extrapolate romIATA (2007) rather than just add the calculated value o ree allowances to the out-o-pocket costs rom eachstudy because not every study identies its assumedallowance price.
16 The changes in ticket prices described above represent
the change in price or the average ticket, with respectto both distance and price. For those studies thatestimated price changes or short-, medium-, and long-haul ights, we included changes in ticket prices or themedium-haul ight. Obviously the EU policy will resultin diferent ticket price changes or ights o diferentlengths, as short- and long-haul ights use diferentamounts o uel and have diferent base ticket prices.
17 On the supply side, pass through depends on thenumber o rms in a market, the concentration o market shares, whether the rms seek to maximizeprots or other objectives, and the ability o other rmsto enter and exit the market. On the demand side, passthrough depends on the number o diferent types o passengers and the willingness o diferent passengersto pay higher prices or a given ticket. For economiststhese actors are maniested in the size o relevant mar-ket and the characterization o the supply and demand
curve. Vivid Economics (2007 and 2008) provide morethorough examination o these issues.
18 This was determined by summing auction percentagesover the relevant modeling horizons and comparingthat to the sum o auction percentages or the actualpolicy.
38 Blue Skies Project | Is the Sky Falling for Airline Profits in theEuropean Union?
Endnotes
19 IATA (2007) assumes a 75 percent pass-through rate,while Ernst & Young (2007) assumes 29 percent to 35percent, and Boon et al. (2007) assumes 1 00 percent. Asdescribed previously the pass-through rate is the keydeterminant in a simple modeling ramework o theextent to which the airlines can increase ticket prices inresponse to increases in costs. This plays a major role insetting changes in revenues, costs, and, thus, prots.
20 Baseline annual prots o covered ights approximatedwith 2010 prots and prot margins in Europe romIATA (2011). We use the 2010 estimate to avoid includ-ing the efects o the EU policy (which may or maynot be included in the IATA orecast or 2012) and as2012 is predicted to be a particularly bad year by IATA,meaning that it may not be a good estimate o averageannual reerence prots under the EU policy.
21 The back-o-the-envelope calculation involves reduc-ing the amount o ree allocation to reect a switchrom 10 percent to 15 percent auctioning. No othermodications are necessary as under the IATA (2007)modeling the amount o ree allocation does not afectchanges in ticket prices or demand. This calculation isuniquely possible with IATA (2007) as it disaggregatesthe components o changes in revenues and costs,specically identiying the value o the ree allocation.
22 Malina et al. (MIT, 2012) also estimate changes inprots, but only or U.S. airlines. As such their resultscannot be used to compare the impact o the EU policyon airlines o diferent nationalities.
23 As noted beore, the Boon et al. (2007) estimateso prot changes seem large, but the direction o the prot changes and distribution o the changesbetween EU and non-EU airlines make s ense. Alsothese prot margins do not appear to be adjusted orcoverage, meaning that the EU policy increases protso non-EU airlines by 0.6 percent relative to the totalprots o non-EU airlines.
24 Ernst & Young (2007) also calculate that cargo will lose$188 million to $727 million.
25 Obviously, these alternatives will only replace certaintypes o air travel. Ships, or example, might replace aircargo or passenger ights over short distances. Theywill probably not substitute or transatlantic ights dueto time cost.
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Advisers helps clients develop and advance environmentally eective, economically
aordable and politically realistic climate change policies, strategies, and investments. I
short, the rm is working with others to actively shape the low carbon economy.