A new dedicated EU policy for alternative fuels in aviation

However, it is unclear whether member states will implement the RED II in a way which will enable a real uptake of advanced fuels in aviation. One way to overcome this would be for the EU to develop a specific amendment to the policy framework, in the form of a dedicated GHG target, i.e. a low carbon fuel standard for sustainable advanced fuels in aviation. Such a standard would require fuel supplied on the EU aviation market to meet a progressively lower GHG intensity by using only sustainable advanced fuels.

At the same time, it would be crucial to ensure that such an additional policy tool does not lead to an increased demand in overall volumes for advanced biofuels compared to what is already required by the RED II.This is especially relevant for sustainable advanced biofuels feedstocks which are available only in limited quantities. Additional growth should be focused on electrofuels - which can be scaled sustainably — and the law should be crafted in a way that achieves this goal.

GHG - low carbon fuel standard for aviation

The Commission could propose an amendment to the REDII which requires suppliers placing aviation fuel on the EU market to comply with a gradually lower carbon intensity. Suppliers would be given several years to meet each level of the GHG intensity target which would apply either across the EU or at the member state level. Member states would be required by EU legislation to enforce the GHG intensity target at the member state level in a similar manner to the way Fuel Quality Directive (FQD) standards are currently implemented. A system of registration of aviation fuel suppliers would need to be established (that for road fuel suppliers was established through the tax provisions of the Energy Tax Directive). The legislation could include a malus/bonus penalty on fuel suppliers for not achieving/over-achieving the requirement. “Aviation fuel suppliers” would need to be defined to include refiners, airport fuel farms and fuel importers, etc.

All fuel uplifted for commercial aviation in the EU would be affected — i.e. for both intra- and extra-EU flights. The retail price of fuel sold to airlines across the EU would rise to reflect suppliers’ higher costs. Safeguards might need to be considered to ensure suppliers did not cross-subsidise higher aviation fuel costs by passing some of the increased costs onto the road sector. The low carbon fuel standard would need to be drafted in such a way as to ensure

Roadmap to decarbonising aviation 163 suppliers acted in tandem across the EU to avoid regional price distortions and potentially airline tankering.

Policy

• • Introduce sufficient safeguards to ensure that sustainable alternative biofuels and electrofuels deliver promised emission reductions without negative consequences on sustainability.
• • Member states should require fuel suppliers to split their advanced fuels target proportionally between land and air traffic and adopt a GHG target/ low carbon fuel standard as this offers the best framework for incentivising the delivery of renewable advanced low carbon fuels.
• • An amendment to the RED II requiring all fuel suppliers placing aviation fuel on the EU market to meet a decreasing carbon intensity, with the purpose of bringing all fuel sold to near zero carbon by 2050.