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Feedback on EU Renewable Energy Rules

Review (Roadmap)



Hereby, Airlines for Europe (A4E) takes the opportunity to submit feedback on the EU renewable energy rules — review (Roadmap).

European airlines are closely exploring pathways towards a net-zero, or low-carbon European air transport through reduction of CO2 emissions in absolute terms and CO2 mitigation (through offsets or market-based measures). It is crucial to recognise the magnitude and urgency of the commitment adopted by the European Commission. Airlines fully understand the importance of not failing to turn this pledge into a future reality. Carrying more than 720 million passengers each year and operating around 3000 aircraft, A4E airlines are ready and willing to contribute to making the European Green Deal a success.

Over the next 10 years, European airlines will invest €169 billion in greener aircraft technologies which emit on average 25% less CO2 and are less noisy than their predecessors. The breadth of knowledge, best practices, track record in efficiency and especially the competencies that Europe’s aviation sector holds are valuable tools in reaching these ambitious goals. Air transport is a prerequisite for achieving many UN Sustainable Development Goals. It represents the right to access essential human needs: jobs, markets and goods, social interaction, education and other services. Improved access helps address general concerns such as socio-economic cohesion throughout the EU or the depopulation of rural areas.

To limit the climate impact of air travel, it is essential that a basket of measures be applied simultaneously to allow European aviation to fully contribute to the climate effort while long-term solutions are implemented to reduce emissions. These include:

  1. Greener aircraft technologies,
  2. More efficient operations and infrastructure,
  3.  The development of appropriate support for sustainable aviation fuels (SAFs), and
  4. Smart economic instruments.


Alongside radical fleet renewal, improved air traffic management and technological advances such as hydrogen and electric propulsion, the use of sustainable aviation fuels (SAFs) is generally considered one of the most effective means to reduce CO2 emissions from aviation in the next decades and a solution that can be applied on short term in the existing fleet, considering that eg. an introduction of a radical fleet renewal will also take a long implementation period.A recent study notably shows that up to 30% of emissions savings can be achieved by 2050 thanks to such fuels. Source: Sustainable Aviation UK, 2019. See also European Aviation Environmental Report 2019, EEA, EASA, Eurocontrol. Currently approved SAFs not only reduce our dependency on fossil fuels but also emit up to 80% less CO2 than regular kerosene. As part of our efforts to make aviation more sustainable, further accelerated by the European Green Deal, we must speed up the development, production and use of drop-in sustainable aviation fuels in Europe.

Many initiatives have been undertaken in Europe since the first commercial SAF flight in 2011. The European Commission, technology companies, the energy industry, airlines and others have invested significant resources in the development of conversion technologies, projects to determine the impact of sustainable fuels in the aircraft, supply networks and scientific studies on the best ways to develop and mobilise the entire value chain in order to incentivise production and voluntary off-take agreements.

Within the Renewable Energy Directive (RED) framework, sustainable aviation fuels can opt-in to contribute to the 14% transport target but are not subject to an obligation (EC, 2019). This means that when sustainable aviation fuels are deployed in a Member State, the Member State is allowed to count these fuels towards its national renewable energy target. For aviation fuels the system includes a multiplier of 1.2. This multiplier allows fuel suppliers to count the contribution of non-food renewable fuels 1.2 times their energy content towards the targets. The inclusion of these options in national regulations depends on political decisions in the transposition processes. According to Art. 27 even a double counting is possible.

In 2012, the EU defined a target of two million tons of SAFs produced in Europe by 2020. Yet, eight years later, production is significantly behind schedule. Well-designed measures to support the development of advanced SAFs are crucially missing and were not sufficiently considered in the 2018 Review of the Renewable Energy Directive (REDII). The cost to produce SAFs is at least three to five times that of conventional jet fuel. Its price is also higher than that of sustainable alternative fuels used in other transport modes. As a result of these higher production costs, SAFs are, in the absence of an orchestrated support strategy, not an economically attractive substitute to conventional jet fuel. 

Policy Recommendations

At present, it remains uncertain which sustainable alternative/aviation fuels have the largest potential in Europe in terms of environmental performance and long-term production cost. It is therefore not surprising that expert views on the issue differ. On one hand, some experts consider the e-fuel route to be the option for Europe, whereas others believe that a mix of various types of sustainable fuels is required in order to meet the expected volumes that will be needed. At this stage, with the challenge ahead of us, we should not make any decisive choices or disregard options with relatively small (volume) potential.With the various technologies occurring it seems that most optimal solutions are partly geographically defined, related for instance to the availability of renewable energy at lower costs in southern countries, bio-waste, or municipal waste. For this reason, to facilitate a variety of technologies to mature, it is important to give each region the opportunity to industrialise its SAF production. All existing and future initiatives require the same long-term perspective and R&D support. Once commercial scale production is possible, initial support to (partially) cover the price premium between sustainable renewable kerosene and fossil kerosene must be secured. Proper European policies and a stable regulatory framework should provide the requested long-term certainty needed to trigger investment in the development, production and deployment of SAF in Europe from high quality feedstock and resources.

A dedicated EU industrial policy for the deployment of innovative aviation fuels through financing and legislation, as foreseen under the planned ReFuel EU Aviation initiativeEuropean Commission Ref. Ares(2020)1725215 — 24/03/2020 is urgently needed.Link to A4E’s position paper on sustainable aviation fuels and recommendations for a revised long-term policy framework to create realistic ROI possibilities: It should include the following key elements:

I. Develop a European policy framework to support SAFs production and deployment with clear objectives, a robust Life Cycle Assessment (LCA)/validation methodology with neutrality towards conversion technologyA wider set of technologies capable of converting unrecyclable solid waste into useful products, such as green fuels and renewable energy, in an environmentally beneficial way. and sustainable raw materials 

SAF production cannot come at the expense of food supplies for people or animals and/or cause damage to the environment as in the case of deforestation. Therefore, these criteria should be solidly embedded in sustainability certification schemes to ensure that only the development and use of truly sustainable fuel are incentivised. Such criteria would benefit both the environment and the aviation industry. Besides, it would de-risk investments.

Currently, the eligibility criteria for advanced biogenic SAF and Renewable Fuels of Non-Biological Origin (RFNBOs) eg. multipliers, or minimum CO2 advantage are unequal. These should be harmonized.

Such a policy framework should last for at least 15 years in order to generate a solid business case and to create confidence amongst investors to step in. The European Green Deal provides an opening to revise the strategic objectives of the RED in conjunction with existing policies and regulatory frameworks. To deliver large volumes of sustainable and affordable SAF, the European Commission should develop the right regulatory framework that ensures the production and use of truly sustainable aviation fuels in Europe in the next decades. With the increased ambition level of the European Green Deal, a revision of the Renewable Energy Directive aligned with global SAF regulations as per the work done at ICAO, assessed by an independent body is necessary. 

II. Feedstock for SAF production 

The existing RED does not provide sustainability guarantees nor the required long-term perspective to build a business and trigger investment. Given the rate of innovation and agility in the sustainability debate, it is recommended to develop a regulatory framework that contains a clear energy/GHG objective combined with a robust, transparent and future-proof certification scheme to ensure delivery is in line with the objective. This SAF or renewable energy system does not benefit from lists allowing or banning particular raw materials or pushing specific technical solutions. The RED and REDII recast need to be reviewed to effectively stimulate the development and deployment of sustainable energy and SAFs. According to economic theory, technology-neutral policy instruments are the most efficient. 

The task of the policy instrument is to provide a predictable regulatory framework, with clear standards for measuring, reporting and verifying set sustainability criteria. The market players intervene then to develop, build, buy and use the best available technology. The incentive structure for advanced biofuels and renewable synthetic fuels should be based on the net sustainability efficiency of the final product, taking into account both the production process and the feedstock. Policy instruments should be designed to help market mechanisms function in the best way possible. Attempts by politicians and regulators to pick technology winners reduce the crucial predictability of the regulatory framework.Early preferences given to certain technologies would advantage/disadvantage certain countries/regions. As higher volumes would be required over time, it is necessary to envision the development and scaling of multiple technologies thereby avoiding possible pressure on singular resources in the medium term. The decision regarding the feedstock types to incentivise should be based on objective and independent sustainability criteria, and not be based on which feedstock is politically acceptable at any given time. These sustainability criteria need to be defined for RFNBOs in particular (eg. carbon source, additionality of electrical supply).

III. Revise the REDII multiplier for SAF providing additional incentives to Member States to include SAF in their RED implementation strategies. 

Competition for feedstock, other inputs and capacity from other sectors (e.g. road transport) for the production of biofuels and electro-fuels has contributed to the current challenges for production and low uptake of SAF. A review of the REDII multiplier for SAFs therefore needs to take into consideration the limited alternatives to fossil fuels for aviation, unlike other modes of transport and road transport in particular. The criteria for SAF from biomass and RFNBOs must be equal.

IV. Put in place a support scheme for SAF technology development and capacity build-up in Europe 

For example, ASTM-approved fuel projects should be subject to a condition to deliver SAF to market through (long-term) purchase agreements whereby at least 70% of the intended production capacity (demo or commercial scale) is committed to a customer (airline). It is precisely this commitment that de-risks investments and is a crucial factor in attracting investors while protecting airlines from unacceptable prices and preventing producers from switching to the production of road transport fuels. In order to increase the availability of SAF across Europe a “book and claim” principle should be considered.

V. Address Europe’s dependency on energy from 3rd countries 

Ensure that the RED revision is in line with Europe’s Energy Security Strategy (ESS). This is important to get the right focus on European feedstock and production in Europe going. Currently, the RED does not make any differentiation of the feedstock and/or fuel’s origin. Import should follow the objectives of the ESS.