The European Commission has been requested by member states to study the incorporation of air transport into their existing emissions trading scheme (ETS). Only CO2 is to be included, at least initially. This paper focuses on the method of allocation of emissions permits in the EU context. It has been assumed here that the EU ETS will be applied only to intra-EU flights and that airlines will be the entities selected for implementation. Three UK airlines were selected to evaluate three main types of allocation: grandfathering, auctioning and benchmarking. The airlines were representative of the three major airline business models: network, low-cost carrier and charter/leisure. Based on 2003/2004 aircraft/engine type and operating data, the per passenger impact of each allocation option was analysed for each airline. A new benchmarking approach is proposed that takes into account both the landing and take-off (LTO) cycle and per kilometre emissions: this avoids penalising shorter sector operators and focuses on the damage caused by aircraft and their engines and not on passengers. (C) 2007 Elsevier Ltd. All rights reserved.