- ReFuel EU: Adjustments on SAF blending targets, feedstock base and cost mitigation are critical to preserve competition and avoid carbon leakage.
- AFIR: A full exemption for the smallest airports to provide electrical ground power to aircraft is needed.
- Positions taken by EU Transport Ministers will help shape aviation’s future decarbonisation, but corrections are paramount.
Brussels and Luxembourg, 02 June 2022 — European Transport Ministers have agreed on two critical Fit for 55 legislative proposals which will shape the future decarbonisation of European aviation: The ReFuel EU Aviation and Alternative Fuels Infrastructure Regulation (AFIR). Once finalised, these two regulations will send important signals to the market and to the public regarding efforts needed to decarbonise air transport both in the air and on the ground. The Council position agreed today will now move to final negotiations with the European Commission and the European Parliament in the coming months before becoming law. During this “trilogue” process, A4E is calling for several adjustments to the two proposals which are critical for Europe’s airlines:
ReFuel EU Aviation: Revert to EC-proposed blending targets and EC definition of sustainable aviation fuel (SAF); Ensure a harmonised EU blending approach and solidify cost support mechanisms (e.g. SAF allowances scheme)
A4E supports the original European Commission (EC) blending targets of 2% SAF by 2025 and 5% SAF by 2030 and urges all parties to align under these targets.
“The original targets as proposed by the EC were ambitious, but realistic. Any higher targets would further erode European airlines’ competitiveness and lead to carbon leakage by creating cost advantages for non-European airlines, especially those with transfer hubs just outside the EU – making non-EU tourism destinations more attractive”, said Thomas Reynaert, Managing Director, Airlines for Europe (A4E).
“A4E supports pricing support mechanisms such as a ‘SAF allowances’ scheme linked to the EU ETS. Such a system would become even more critical for airlines once targets would increase”, Reynaert added.
Classification of sustainable aviation fuel: It is essential that passengers trust that the ramp up of sustainable aviation fuels in the coming years will not occur at the expense of food supplies for people or animals, nor damage our environment.
“We urge policymakers to revert to the European Commission definition of ‘sustainable aviation fuel’ and not broaden the definition of SAFs to include non-sustainable feedstock that competes with food or feed production, or which leads to deforestation. SAFs must be truly sustainable without any compromise – full stop”, Reynaert added.
Common SAF blending approach at EU level (no national mandates): To ensure the integrity of the EU single market for aviation, A4E is also calling for a harmonised EU blending target, rather than higher diverging national targets, as agreed today by the Transport Ministers.
Alternative Fuels Infrastructure Regulation (AFIR): Adjustments needed on scope of regulation requiring airports to supply electricity to stationary aircraft, and funding for green airport infrastructure investments
A4E generally supports the AFIR proposal, even if the estimated carbon reduction is modest at 0.3% – 1% of total aviation CO2 emissions. We welcome the Council’s introduction of a threshold which would exempt small airports with less than 10,000 commercial movements per year from supplying electricity at remote stands. However, we believe this threshold should apply to both contact stands (gates) as well as remote stands out on the apron. The threshold would still include the vast majority of European airports in AFIR’s scope.
“Small airports, especially those in peripheral regions, account for a low volume of short-haul flights. The required AFIR investments and operating costs would be disproportionate in relation to the potential emissions savings it would generate. Small airports in Europe should therefore be exempt from this measure altogether”, Reynaert said.
Finally, it’s important that airport investments in “green” infrastructure are not passed onto airlines through higher airport charges. Given the substantial investments and costs associated with the Fit for 55 package overall, A4E is calling for funding to be made available to airports directly – for example through the Connecting Europe Facility – to undertake infrastructure investments such as providing electrical ground power to aircraft. These investments must also meet the requirements of the Airport Charges Directive (2009/12/EC), including consultation between airlines and airports, transparency on airport costs and independent regulatory oversight.
Jennifer Janzen, Communications Director, A4E, +32 499 828294 firstname.lastname@example.org