Corporate members of the Sustainable Aviation Buyers Alliance (SABA) have committed to purchasing sustainable aviation fuel certificates (SAFc) for nearly 50 million gallons of SAF, with an investment value of close to $200 million. The multi-year collection of deals, which involves 20 corporate customers, four fuel providers and three airlines, has the potential to reduce around 500,000 tons of CO2e. Purchasing SAF certificates enables corporate travellers to invest in SAF and capture the environmental benefits, allowing them to make GHG emissions reduction claims on their climate disclosures, while the physical SAF flows to an aircraft operator. SABA is working with airline partners Alaska, JetBlue and Southwest, securing certificates through SkyNRG and purchasing directly from fuel providers including World Energy.

“Creating an ecosystem that equips companies from all economic sectors to access more SAF is part of our mission,” said Adam Klauber, VP Sustainability and Digital Supply Chain at World Energy, the world’s first commercial-scale SAF producer. “We are proud to collaborate to help Scope 3 customers achieve their net zero goals and dramatically increase SAF production with these long-term contracts.”

SABA said multi-year deals were essential in driving scale in the SAF market as long-term certainty about demand helped fuel producers secure financing for their projects and so bring more SAF to market.

“SABA plays a critical role in helping companies identify and purchase the highest-integrity sustainable aviation fuels to accelerate progress towards net zero goals,” said Elizabeth Sturcken, Managing Director at Environmental Defense Fund (EDF), which co-founded the alliance.

Different fuel types are being purchased through the set of agreements, including power-to-liquids, or e-fuels, produced from renewable electricity and CO2 by startup Twelve, and offered in partnership with Alaska.

As global demand for aviation and SAF grows, partners like SABA will be increasingly crucial to bring the full range of aviation stakeholders to the table,” said Nicholas Flanders, co-founder and CEO of Twelve. “Innovative power-to-liquid fuels will deliver deeper emissions reductions but need the support of airlines and corporations in order to scale. We’re proud to join with SABA and its collective of forward-minded corporate customers, airlines and fellow fuel providers to deliver E-Jet fuel and help pioneer the market for high-integrity SAF certificates.”

The new RFP multi-year purchase follows a pilot SAFc procurement for nearly 850,000 gallons of SAF last year. By expanding the process to include multiple fuel providers and airlines, customers are able to invest in a range of fuel types and help bring new technologies to market, said SABA.

“As we continue to optimise our business travel emissions, we recognise the crucial role that lower carbon air travel plays in meeting global climate targets,” commented David Webb, Chief Sustainability Officer of BCG, a SABA member. “The SAF industry is rapidly evolving and we are enthusiastic about its potential to scale and support a more sustainable, global economy.”

EDF and SABA’s other co-founder, RMI, have developed the digital SAFc Registry that was launched during COP28 in Dubai last December, which is being used as the central platform to record the certificates purchased through the RFP. Building on industry best practices, the registry creates an auditable ledger to ensure the certificates realise their intended environmental impact and can be claimed towards emissions reduction goals.

“The SAFc Registry plays a critical role in the SAF ecosystem by bringing greater consistency and transparency to SAFc transactions, building trust along the SAF value chain and helping send a strong demand signal for the low-carbon fuels needed to decarbonise the aviation sector,” said Bryan Fisher, Managing Director at clean energy non-profit RMI.

Plans for a new collective procurement process are underway, although SABA cautioned available SAF volumes that met its requirements “came nowhere close” to meeting the full demand from its customers in 2024 and 2025.

“The only way to drive structural change in hard-to-abate sectors like aviation is to shake up existing business models,” said Kim Carnahan, Head of SABA’s Secretariat and CEO of Neoteric Energy and Climate. “The recent announcement from the Science Based Targets initiative opening the door to the use of market-based approaches to address Scope 3 emissions only elevates the importance of SABA’s book-and-claim system as an innovative and environmentally robust avenue for customers to drive aviation decarbonisation.”

SABA is hosting a webinar on May 1 that will discuss the latest multi-year RFP SAFc procurement. Details here

Photo: Alaska Airlines

Christopher Surgenor

Editor

• Linkedin

RSB and Air bp announced their partnership in a sustainable aviation fuels (SAF) book and claim pilot earlier this year and, as part of the pilot, were joined by Microsoft, United Airlines and the Sustainable Aviation Buyers Alliance (SABA) to record the first transaction in the RSB book and claim register. With an approximate 80% reduction in lifecycle emissions in comparison with fossil jet fuel, 7,000 gallons (21 tonnes) of waste-based SAF were supplied by Air bp to United Airlines at UK airports. The sustainability attributes of the fuel were purchased by and credited to Microsoft, a founding company of SABA, which is managed by RMI and the Environmental Defense Fund, reports Susan van Dyk. The transaction was audited and verified by RSB, and the SAF credits were recorded in a book and claim register and retired by Microsoft after the fuel was used. Experience from the pilot scheme, together with broad stakeholder consultations, are contributing to the development of a book and claim manual by RSB, which will establish the rules for a robust, credible and transparent system that verifies the emission reductions achieved while avoiding double counting. Bryan Fisher, Managing Director of RMI’s Climate-Aligned Industries programme, said the book and claim system was “a gamechanger” for the SAF market.

“Virtual ownership of SAF’s environmental attributes can accelerate the technology by unlocking new payers and their resources, and that is why SABA has prioritised participation in this pilot,” he said.

A book and claim system allows the separation of the physical SAF from its sustainability attributes and permits a company to purchase and claim the emission reductions from SAF use regardless of the physical fuel supply location. The company purchasing the sustainability attributes does not use the physical fuel, but claims the SAF credits, which represents a volume of CO2 emissions prevented. In this case, Microsoft purchased 21 SAF credits, representing 21 tonnes of SAF, resulting in a reduction of 53 tonnes of CO2 (calculated on the basis that one tonne of fuel emits 3.16 tonnes of CO2 and an 80% lifecycle reduction). As the customer does not have to use the fuel, purchasing the SAF credits are not limited to fuel users such as airlines but can be done by any company who wants to reduce their Scope 3 emissions.

United and Microsoft have previously purchased SAF, but this was the first time SAF environmental attributes have been transferred using RSB’s book and claim system. RSB is developing the system with input from multiple stakeholders across the aviation value chain, including airlines, fuel producers, corporate customers and others. Feedback from stakeholders and learning experiences during the pilot scheme will help RSB to develop rules in a book and claim manual as a guide for a robust, credible and transparent system that can be used by any stakeholder.

Transactions under a book and claim system will be recorded in a registry, which SABA will be developing in collaboration with RSB and Clean Skies for Tomorrow (CST), said Kim Carnahan, SABA Secretariat Lead and Senior Director Net Zero Fuels at ENGIE Impact. This universal electronic ledger or registry will be compatible with the RSB book and claim system, which will detail the rules for how credits can be booked and claimed. Carnahan further explained that the book and claim manual would allow environmental attributes from any SAF certified by RSB and ISCC to be claimed under the system.

The greatest concern with book and claim transactions is the risk of double counting occurring when SAF emissions may be counted more than once towards a climate mitigation effort. Pedro Piris-Cabezas, Director of Sustainable International Transport and Lead Senior Economist at the Environmental Defense Fund (EDF) discussed the risk at the recent RSB Annual Conference. Avoiding double counting starts with a robust book and claim system from an ICAO-approved Sustainability Certification Scheme such as RSB, he explained, with transactions recorded in a registry.

While there is a risk of double counting between air carriers and corporations, the accounting of emissions reductions by countries in their national inventory reports also poses a risk for double counting. Piris-Cabezas recommends the fuel supplier must secure a commitment from the host country to report the SAF as international bunker fuel in its national inventory reports to ensure that emissions reductions are not claimed twice. Under UNFCCC rules, international bunker fuels (aviation and shipping) are reported separately and are a source of emissions not addressed under countries’ Nationally Determined Contributions (NDCs). Piris-Cabezas also highlighted the potential impact of a country’s policy environment and incentive schemes for SAF purchase under a book and claim system as a fuel producer would not be able to claim emission credits for the same SAF. SABA is providing guidance on how to simultaneously address UK policy requirements (as the SAF for the pilot was supplied and used in the UK) and recognise the emissions benefits for voluntary corporate purchases.

According to Elizabeth Willmott, Carbon Program Manager at Microsoft, the pilot offers the opportunity to ensure transparency and credibility for environmental claims for SAF purchases. RSB’s new Executive Director, Elena Schmidt, welcomed the participation of Microsoft and United in the RSB pilot project, which she said “took the pilot into the real world”. Microsoft’s commitment to sourcing RSB-certified fuel is an example of how companies can use their buying power to drive positive impacts, even outside their direct supply chains, she added.

Kelley Kizzier, EDF’s VP Global Climate, said SABA was looking forward to applying the lessons learned from the pilot to the development of an electronic book and claim registry, alongside RSB, so that more air transport customers could benefit.

At the recent COP26 climate talks in Glasgow, SABA announced the addition of an Aviators group to their membership, formed by Amazon Air, Alaska Airlines, JetBlue and United Airlines. SABA said the new group would help “send even stronger demand signal to drive greater SAF production, price reduction and technological innovation”. EDF and RMI also unveiled SABA’s formal membership structure at the COP26 event, opening membership opportunities to airlines, companies and non-profit organisations.

SABA was launched by RMI and EDF in April 2021 with founding members Boeing, Boston Consulting Group, Deloitte, JPMorgan Chase, Microsoft, Netflix, Bank of America, McKinsey & Company, and Salesforce, with Meta (formerly Facebook) later joining as a founding member.

Photo: SABA’s Kim Carnahan presents the initiative during COP26. The event included a keynote from US Transportation Secretary Pete Buttigieg and a panel session with representatives from United Airlines, Alaska Air, Amazon, McKinsey & Company and Deloitte. A YouTube video recording is available here

Susan van Dyk

GreenAir Correspondent

www.svdconsulting.ca

• Linkedin

US government departments and agencies have joined with the aviation and fuel sectors to agree a stimulus package to put US aviation on track to achieve net zero greenhouse gas emissions by 2050. It includes new and ongoing funding opportunities to support sustainable aviation fuel (SAF) projects and fuel producers totalling up to $4.3 billion in efforts to boost production of SAF to at least 3 billion gallons per year by 2030 under a ‘Sustainable Aviation Fuel Grand Challenge’ initiative. Through their trade body A4A, US airlines pledged in March to work towards making 2 billion gallons of SAF available by 2030 but are now increasing that goal by an additional 50%. The Biden administration also announced its backing for a SAF tax credit to incentivise and scale up production as part of its Build Back Better green agenda. Also announced were an increase in R&D activities on new technologies to spur developments in aircraft fuel efficiency and efforts to improve air traffic and airport efficiency. The administration said it would be strengthening its aviation and climate change leadership internationally and will support the adoption at ICAO of a long-term aspirational goal for reducing aviation emissions.

“President Biden is taking steps to coordinate leadership and innovation across the federal government, aircraft manufacturers, airlines, fuel producers, airports and non-governmental organisations to advance the use of cleaner and more sustainable fuels in American aviation,” said a White House fact sheet released after a roundtable on sustainable aviation held on September 9. “These new agency steps and industry partnerships will transform the aviation sector, create good-paying jobs, support American agriculture and manufacturing, and help us tackle the climate crisis.”

Responded A4A President Nicholas Calio, who attended the White House meeting: “We are proud of our record on climate change, but we know the climate change challenge has only continued to intensify. Accordingly, A4A member carriers have embraced the need to take even bolder, more significant steps to address the climate crisis.”

Commercial flights contribute 11% of US transportation-related emissions and 2% of the nation’s total. “Without increased action, aviation’s share of emissions is likely to increase as more people and goods fly. That is why leadership and innovation in this sector is so essential if we hope to put the aviation industry, and the economy on track to achieve net zero greenhouse gas emissions by 2050,” says the Biden administration.

“Achieving a sustainable aviation industry requires energy efficiency improvements in aircraft technology and better operations. In the future, electric and hydrogen-powered aviation may unlock affordable and convenient local and regional travel. But for today’s long-distance travel, we need bold partnerships to spur the deployment of billions of gallons of sustainable aviation fuels quickly.”

Current levels of domestic SAF production are around 4.5 million gallons per year. Jet fuel consumption from domestic and outgoing international flights totalled 19.2 billion gallons in 2019, according to the Bureau of Transportation Statistics, still lower than peak consumption years but had been edging up since 2015 prior to the Covid-19 pandemic. A 3-billion-gallon goal therefore represents a 15% share of total jet fuel consumption being taken up by SAF in 2030, if based on 2019. The actions taken, says the administration, will enable aviation emissions to drop 20% by 2030 when compared to business as usual if the goal is met.

The proposed SAF tax credit requires a minimum 50% reduction in lifecycle GHG emissions and so offers an increased incentive for greater reductions. The Department of Energy (DOE), Department of Transportation (DOT) and US Department of Agriculture (USDA) are to support SAF producers through the new Grand Challenge initiative in order to work with stakeholders to reduce costs, enhance sustainability and expand production and use of SAF that meets the 50% lifecycle reduction. In addition to the 2030 goal, the target is to meet 100% of aviation fuel demand with SAF by 2050, which is currently projected to be around 35 billion gallons per year. In a series of actions to be taken:

• USDA will support US farmers with climate-smart agriculture practices and research, including biomass feedstock genetic development, sustainable crop and forest management at scale, and post-harvest supply chain logistics. USDA will also support fuel producers with carbon modelling components of aviation biofuel feedstocks.
• The Environmental Protection Agency and DOE will collaborate to identify data collection needs, assess technical information and take other steps designed to expedite the regulatory approval process to support newly developed fuels and feedstocks that might be viable for inclusion as able to generate Renewable Identification Numbers (RINs) under renewable fuel in the Federal Renewable Fuel Standard programme.
• The FAA will make 14 grant awards with FY21 funds to the Aviation Sustainability Center (ASCENT) totalling more than $3.6 million. This will support the SAF approval clearing house in conducting evaluation testing to ensure that new fuels are safe for use.

Other funding initiatives include the DOE Bioenergy Technologies Office’s already announced $35 million for 11 projects developing feedstock and algae technologies for advancing the domestic bioeconomy, plus a new additional $61 million to advance biofuels and support the reduced cost of SAF pathways, including 11 projects that are scaling up promising technologies to produce SAF. The DOE is also offering up to $3 billion in loan guarantees, with commercial-scale SAF projects that utilise innovative technology and avoid, reduce or sequester GHG emissions and meet other requirements potentially eligible. Department of Defense (DOD) funding, subject to appropriations, is to be made available to certify the use of up to four additional SAF pathways already approved in the commercial market, as well as additional SAF pathways in the ASTM approval pipeline for military aircraft.

Further initiatives, collaborations and funding have been announced by NASA, FAA, DOD and DOE to achieve at least a 30% improvement in aircraft fuel efficiency, improving air traffic and airport efficiency to reduce fuel use, eliminate lead exposure and ensure cleaner air in and around airports.

The administration says it plans to release an aviation climate action plan in the coming months. It also commits the United States “to asserting positive leadership on aviation and climate change.

Adds the White House statement: “As a country, we will re-establish US credibility through ambitious domestic commitments and realistic action plans for implementing those commitments, demonstrate leadership on aviation ambition at the International Civil Aviation Organization by showing the world by implementing CORSIA transparently and effectively, and supporting adoption of a long-term aspirational goal for reducing aviation emissions. We will also engage with bilateral and regional partners to forge a diverse coalition of States committed to greater ambition and action on aviation.”

In addition to representation from the aviation and SAF production sectors, the roundtable was also attended by Fred Krupp, President of Environmental Defense Fund (EDF) and Jules Kortenhorst, CEO of RMI, which are spearheading the recently-formed Sustainable Aviation Buyers Alliance (SABA).

“In the coming months, the administration will be challenged to develop a methodology to determine the environmental criteria to ensure that only high-integrity SAF receives public support. The administration’s call for credibility and consistency with the international community, including ICAO, makes us optimistic. EDF and our partners in SABA are up to the task of ensuring that SAF contributes effectively to decarbonisation,” said Pedro Piris-Cabezas, EDF’s Director for Sustainable International Transport.

Photo: Alaska Airlines

US Democrat Senator Sheldon Whitehouse has introduced a new bill, the Sustainable Aviation Fuel Act, that sets a goal of achieving a net 35% reduction in US aviation greenhouse gas emissions by 2035 and net zero emissions by 2050. The bill, S. 1608, would create a grant programme authorised at $1 billion over five years to expand the number of US facilities producing SAF and build out the necessary supporting infrastructure. It also requires the Environmental Protection Agency to establish an aviation-only low carbon fuel standard that regulates aviation fuel producers and importers. The bill also calls for a new blender’s tax credit that was included in proposed legislation introduced in the House of Representatives by Congresswoman Julia Brownley in February, although she is now co-leading a new House bill, the Sustainable Skies Act, which has just been introduced by Congressman Brad Schneider that would also create the tax credit. The Schneider bill has received support from the US airline industry, US NGOs and SAF producers. Meanwhile, the US Department of Energy has announced funding of $35 million towards research into optimising biofuel manufacturing to reduce carbon waste, with an award going to alcohol-to-jet technology company LanzaTech.

“Air travel connects the world in all kinds of important ways but comes with a high price for our climate,” said Whitehouse, a strong advocate for policies addressing climate change, environmental protection and a price on carbon, on the introduction of his bill, S. 1608. “The best solution is to transition away from fossil jet fuels and encourage the production of sustainable fuel alternatives that are just as safe for passengers and much safer for the planet.”

Whitehouse said in a press statement that although sustainable aviation fuel (SAF) was starting to be produced both in the US and internationally, it wasn’t at a scale fast enough to achieve long-term climate change goals.

“The same feedstocks used to produce SAF are also used to produce renewable diesel, which is primarily for ground transportation,” said the statement. “If not corrected, the lack of policy incentives to produce SAF rather than cheaper renewable diesel will have long-term consequences for the climate.”

Added Californian Senator Dianne Feinstein, who is co-sponsoring the legislation: “Air travel is a significant contributor to climate change and we need to take strong action to reduce its emissions. This bill complements California’s low carbon fuel standard so aviation fuel can be used closer to where it’s produced.”

As well as the $1 billion grant programme and the establishment of a Low Carbon Aviation Fuel Standard under the Clean Air Act in which parties will have to comply with a carbon intensity benchmark that declines each year, the Act would require the FAA to conduct additional research on ways to increase SAF utilisation in the aviation sector and require the Department of Defense to increase SAF utilisation to 10% from 2024, so long as it was cost competitive with fossil jet fuel and readily available.

It would also expand the existing energy investment tax credit to include SAF production facilities and related infrastructure. The credit would be a 30% credit through 2026 and then falling in stages to 12% from 2029 to 2035, at which point it would fully phase out.

The Act finds common ground with the Schneider proposed legislation in establishing a blender’s tax credit for SAF of between $1.50/gallon and $1.75/gallon, depending on the reduction of GHG emissions achieved by the SAF, although the Whitehouse bill would scrap SAF eligibility for the existing $1/gallon biodiesel tax credit in order to prevent ‘double dipping’.

Under the Schneider legislation, the £1.50/gal tax credit would apply to blenders that supply SAF with a demonstrated 50% or greater lifecycle estimate reduction in GHG emissions compared to standard jet fuel. In order to incentivise greater reductions in emissions, his legislation provides an additional credit of $0.01/gal for each percentage the fuel reduces emissions over 50%, so a SAF that reduces emissions by 70% would receive a credit of $1.70/gal. The tax credit would expire at the end of 2031.

To ensure environmental integrity, the legislation would exclude palm fatty acid distillates (PFAD) as an eligible feedstock “due to its detrimental environmental record” and would require eligible SAFs to conform with the full ICAO sustainability criteria, including accounting for both aggregate attributional core lifecycle emissions and the induced land use change.

Rep. Brad Schneider: “Implementing sustainable aviation fuels is the single most important step the aviation industry can take to combat climate change and I’m proud to take this legislation to the House”

“Air travel has changed the world and will be a growing part of our future. It is imperative for America to confront the existential challenge of climate change by making air travel cleaner,” said Schneider, an Illinois representative, in a press statement. “The Sustainable Skies Act will halve carbon emissions while also enabling more travel and commerce, a win-win for Americans today and our future generations.

“Implementing sustainable aviation fuels is the single most important step the aviation industry can take to combat climate change and I’m proud to take this legislation to the House with the support of both Illinois-based companies like United and LanzaJet, and climate change champions like the Environmental Defense Fund (EDF) and the World Wildlife Fund (WWF).”

United Airlines CEO Scott Kirby described the Act as a critical step on the path the decarbonise his airline and the broader airline industry, while Nicholas Calio, President of industry body Airlines for America, said the measure would go a long way towards improving the cost-competitiveness of SAF.

“The US airline industry has set a goal of making 2 billion gallons of environmentally-friendly SAF available for US carriers to use in 2030 and supportive measures like this will enable us to achieve that goal,” said Calio.

The Act has the support of two unions, the Air Lines Pilot Association (ALPA) and the Association of Flight Attendants-CWA.

“Flight attendants know first-hand the threat climate change poses to our safety and our jobs – increased turbulence, extreme weather events and more,” said Sara Nelson of the union that represents 50,000 flight attendants at 17 airlines. “We urge Congress to act urgently to support the production and use of SAF and reduce the aviation industry’s reliance on petroleum-based jet fuel, ensuring real reductions in aviation emissions. The time for investment is now.”

Added ALPA’s Capt Bob Fox: “From our flight deck window, airline pilots have a rare perspective on the earth. We see the droughts, forest fires and storms that are linked to climate change but our view is also shaped by practices and policies that already allow us to contribute to a cleaner environment. Airline pilots are eager to do even more to protect our planet and that’s why ALPA supports the Act.”

Paul Bledsoe, Energy Fellow and strategic advisor at the Progressive Policy Institute, said passing the Act “is the single most important near-term action Congress can take to reduce GHG emissions from aviation. Right now, SAF is not widely available, so durable tax incentives are needed to jumpstart much higher production and use, and to reduce long-term costs so the credit can be phased out after a decade. This crucial legislation should be included in infrastructure bills Congressional tax committees are writing and passed into law at the earliest opportunity.”

EDF’s SVP for Climate, Nat Keohane, told a media call hosted by Schneider that it was important sustainable fuels were genuinely sustainable and that the Act created the right incentives, and that it was performance based and excluded some of the most problematic pathways of the past.

“It is designed so that the incentive grows with the carbon benefit and we’re excited about the broader environmental safeguards, with a rigorous sustainability criteria that the US government helped to put in place at ICAO so that only those fuels with the highest integrity get the tax credit. This will ensure, for example, that biofuels from deforested land don’t qualify, which is a critical aspect. We are also pleased the bill provides for e-fuels, or power-to-liquid fuels, which will be a key part of the mix going forward,” he said.

With two similar pieces of legislation being introduced in Congress at the same time, EDF and WWF are supporting both.

“We supported the original bill introduced in the US House of Representatives by Congresswoman Brownley, and Senator Whitehouse introduced the companion bill in the Senate last week,” Kelley Kizzier, EDF’s VP Global Climate, explained to GreenAir. “We see these as complementary, a continuation of our partnership. Representative Brownley’s Sustainable Aviation Fuel Act reflects a comprehensive approach, including a blender’s tax credit provision and a national goal for decarbonising the aviation sector. The Sustainable Skies Act focuses on the blender’s tax credit and allows us to go deeper into this element of the broader decarbonisation agenda to introduce robust environmental safeguards.”

Brad Schallert, WWF’s Director of Carbon Market Governance and Aviation, said: “Aviation emissions are projected to triple by 2050 but there is a route for the aviation industry to support a climate-safe and more environmentally sound future for the planet. Powering planes with SAF is an indispensable step along this journey and Congress can help realise it by passing Senator Whitehouse’s Sustainable Aviation Fuel Act.”

Industry though is throwing its weight behind the Schneider bill. “The blender’s tax credit may be able to move forward to adoption more quickly than a SAF bill with many components, thus helping to support the scale-up of SAF production and bringing related GHG emissions savings, jobs, energy security and other benefits in the nearer term,” a source told GreenAir.

Others supporting the Schneider bill include Third Way, the Rocky Mountain Institute, the Biotechnology Innovation Organization and some US aviation trade associations. As well as Brownley, the bill is co-led by Congressman Dan Kildee, and Democrat Senator Sherrod Brown is expected to introduce a Senate companion bill shortly.

Rep. Julia Brownley: “There’s a lot more to be done but we’ve made extraordinary progress and the Biden administration is now supporting the blender’s tax credit and we look forward to the continued work and advocacy to move this bill forward”

“The United States can be a leader in the shift to cleaner, more sustainable fuels that will create good-paying jobs across the aviation sector,” said Brownley. “I’ve been pleased to work on the blender’s tax credit provision with Congressmen Schneider and Kildee, together with a broad coalition of stakeholders. The Sustainable Skies Act we are introducing is a consensus proposal that has the support of environmentalists, airlines, SAF producers and labour, and this clearly demonstrates that SAF policy can be both a win for the environment and a win for the economy. There’s a lot more to be done but we’ve made extraordinary progress and the Biden administration is now supporting the blender’s tax credit and we look forward to the continued work and advocacy to move this bill forward.”

Brownley told the media call she still supported components in her own bill that are now in the Whitehouse bill, such as on SAF production infrastructure and the Low Carbon Aviation Fuel Standard. “I am continuing to work on all of this – it’s just that parts of my bill are longer term but this [the Sustainable Skies bill] can be done now and really be an engine to move this industry forward.”

Jeremy Baines, President of SAF producer Neste US said the blender’s tax credit legislation was a practical solution that could be immediately deployed and accelerate the production and use of SAF. LanzaJet CEO Jimmy Samartzis said a long-term, performance-based blender’s tax credit would allow his company to be able to invest in and produce SAF at scale across the nation.

The Whitehouse bill requires the FAA’s Center of Excellence for Alternative Jet Fuels and the Environment to conduct additional research on ways to increase SAF fuel utilisation in the aviation sector and the impact of aviation emissions on the climate crisis. It also requires the Department of Energy (DOE), in consultation with the Department of Agriculture, to research the use of cover crops in the production of SAF.

Meanwhile, the DOE’s Advanced Research Projects Agency-Energy (ARPA-E) has announced a total of $35 million in funding awarded to 15 research projects towards advancing new technologies to decarbonise biorefining processes across the energy, transportation and agriculture sectors. It said biofuels, including ethanol, biodiesel and other products derived from organic material, are almost exclusively produced via a fermentation conversion process that create carbon as a by-product, with some processes wasting more than a third of this carbon as CO2. As a result, says DOE, there is a critical need to create new pathways for biofuel conversion that reduces carbon waste, prevents the loss of CO2 emissions and, in turn, maximises the amount of renewable fuel a conversion process yields.

“Biofuel is a powerful tool in the clean energy toolkit that has immense potential to power our ships and airlines with zero carbon emissions,” said Secretary of Energy Jennifer Granholm. “DOE is investing in research to reduce emissions and maximise the availability of efficient biofuel as we strive to reach President Biden’s net-zero carbon goals.”

Most of the recipients of the funding are universities and laboratories but an award of $4.1 million has been made to alcohol-to-jet fuel pioneer LanzaTech. The company, which will partner with the University of Michigan and Oak Ridge National Laboratory, says the funding will be used to enhance existing technology to enable the direct conversion of CO2 to ethanol at 100% efficiency. It will develop a gas fermentation process that leverages affordable, renewable hydrogen to directly capture and fix CO2 into fuels and chemicals while limiting emissions of CO2 into the atmosphere. The carbon optimised conversion technology developed under the project can be integrated within multiple CO2 sources, such as corn grain ethanol refining and direct air capture to create a new carbon economy, said LanzaTech.

Photo: United Airlines

A group of America’s most prominent companies have become founder members of a partnership set up to drive investment in high-quality sustainable aviation fuel (SAF). The Sustainable Aviation Buyers Alliance (SABA) is an initiative of RMI and Environmental Defense Fund (EDF), with founding members Boeing, Boston Consulting Group, Deloitte, JPMorgan Chase, Microsoft, Netflix and Salesforce. A significant portion of the members’ carbon footprint results from business travel and by purchasing SAF, these corporations will be able to access the GHG reductions associated with SAF to directly mitigate their travel carbon footprint. SABA aims to create an aggregated demand for SAF, sending a potentially strong market signal for SAF which it expects will boost development of SAF production and investment into the sector, reports Susan van Dyk. According to RMI’s Adam Klauber, demand created by SABA could amount to 2 billion gallons of SAF by 2025, a significant volume based on current SAF production, which is less than 0.01% of current jet fuel demand.

SABA says its mission is to accelerate the path to net zero aviation through high-quality SAF, catalysing new SAF production and technological innovation and supporting member engagement in SAF policy-making. It has set out three objectives:

• Expand the SAF investment opportunity by establishing an environmentally rigorous, transparent SAF certificate system, and develop an approach to aggregate member demand to incentivise new SAF supply;
• Provide education and policy support to members; and
• Assess emerging SAF technologies and address barriers to scale and cost reduction.

Even during the best of times, airlines operate on slim margins and have a limited ability to pay high premiums for SAF, which can range from three to six times higher than conventional jet fuel, although a number of major airlines have offtake agreements in place with potential SAF producers to narrow the price gap. Long-term development and commercialisation of SAF will require policy intervention to create a market demand and bridge the gap.

In the absence of such policies, SAF use may be limited to airlines willing to pay the price premium, funded through increased ticket prices or other mechanisms that may affect airline competitiveness. SABA’s members, on the other hand, could more readily pay a premium for SAF, said Adam Klauber, Senior Technical Advisor at RMI (formerly Rocky Mountain Institute), who leads its sustainable aviation team.

According to SABA Secretariat lead Kim Carnahan, Director of Disruption Technologies at ENGIE Impact and former US Chief Negotiator for Climate Change, “A large, growing number of companies have committed to ambitious climate goals and are focusing on driving reductions within their value chain.”

Added Microsoft’s Carbon Program Manager, Elizabeth Willmott: “We have a bold commitment to become carbon negative by 2030 and this requires us to create innovative new solutions and partnerships. As a corporate buyer and vocal supporter of high-quality SAF, we’re pleased to join together with companies leading on climate action to support SABA’s mission to decarbonise aviation and ultimately increase SAF production and adoption.”

Many corporations indirectly contribute to aviation emissions through business travel. The Boston Consulting Group, for example, indicate that business travel constitutes about 80% of the company’s carbon footprint. As they are not direct users of jet fuel, they cannot directly use SAF to mitigate these emissions, but Environmental Attribute Certificates (EACs), or SAF certificates, can be used to reduce this climate impact. Indirect emitters are willing to pay the premium but cannot take ownership of the fuel and EACs allow them to access the reductions within their value chain.

“SABA adds momentum to existing airline-company partnerships that support the purchase of sustainable aviation fuels,” said Kelley Kizzier, Vice President of the Global Climate programme at EDF. “SABA will build on the work of these early movers, many of whom seek a more scalable, standardised approach, by establishing a SAF certificate system with robust environmental criteria. Working with sustainability certification schemes, this system will verify and track emission reductions from SAF so that companies, organisations and even individual travellers can achieve their ambitious climate goals.”

Similar to a book-and-claim system, the environmental attributes of SAF will be decoupled from the physical fuel and tracked as SAF certificates using digital markers. The SAF certificate system includes:

• a lifecycle assessment approach;
• sustainability criteria; and
• a tracking and verification approach to create a SAF traceability system and a SAF certificate registry system, established alongside approved sustainability certification schemes under ICAO’s Carbon Offsetting and Reduction Scheme (CORSIA).

The registry system will be designed to be publicly available and transparent, holding the SAF certificates purchased by companies and document retirement of certificates.

“SABA builds off the foundational SAF sustainability work under ICAO and the ‘Corporate Demand’ approach developed with the World Economic Forum’s Clean Skies for Tomorrow,” said Klauber.

A commonly used method of climate mitigation is the purchase of carbon offsets and this forms the basis of CORSIA. However, other studies, including a recent report from the Energy & Climate Intelligence Unit and Oxford Net Zero, argue offsets do not always provide fully additional effort, and reliance on them may present risks to effective mitigation. A clear conclusion from the report is that offsetting cannot be a substitute for significant emissions cuts. Net zero pledges can play a central role in guiding the ongoing emissions reductions needed to deliver the Paris goals, it says, but adds “analysis shows that these commitments vary hugely in their quality”.

SABA members, in contrast, have used Science Based Targets (SBT), an initiative to drive ambitious climate action in the private sector, which espouses a mitigation hierarchy that prioritises eliminating sources of emissions within the value chain. According to SBT, carbon offsets can only be used as a last resort. SBT helps companies set targets for reducing their carbon footprint and uses a scientific basis to verify targets in accordance with the Paris Agreement. The purchase of SAF and acquiring of SAF certificates therefore reduces the climate impact within the aviation sector where emissions are created.

The SAF market is nascent with significant challenges and current availability of SAF is limited. SABA will contract with SAF producers to purchase SAF certificates through RFPs, the first to be issued in Q1 of 2022. Using a 10-12 month lead time for delivery of SAF certificates will enable SAF producers to ramp up production and allow a broader group to SAF producers to participate as only two SAF producers can currently supply commercial volumes of fuel. This will support the creation of new and additional SAF supply capacity and send increased revenue to fuel suppliers, as well as enhance price transparency and competition in the SAF market.

Founding members will be limited to 12 corporations but according to Carnahan, SABA is planning to open up to broader membership after an official launch at COP26 in November. With a large membership, the aggregated demand for SAF could have a significant impact on SAF development and commercialisation, believes the alliance.

Scott Corwin, Deloitte US Leader for Sustainability and Climate Change, said: “Efforts such as SABA are important to harnessing the power of the market to set in motion and sustain the innovations needed to create a zero-carbon future.”

Fellow SABA member Dr Emma Stewart, Sustainability Officer at Netflix, added: “It’s impossible to stabilise the climate without decarbonising aviation emissions. Air travel plays an important role in how Netflix entertains the world – we can’t produce films, TV series and nature documentaries without it. We’re co-founding SABA to build a future where climate-friendly air travel is possible and invite other companies to join the charge.”

Said Carnahan: “This is just the beginning for SABA. We will announce additional founding companies soon.”

Photo: Alaska Airlines

Susan van Dyk

GreenAir Correspondent

www.svdconsulting.ca

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ICAO’s governing Council has adopted decisions on eligible carbon emissions units and sustainability certification schemes for eligible fuels that the UN agency says are the final building blocks for the CORSIA carbon offsetting mechanism for international aviation, which formally starts next month. At its 221st session, the Council accepted recommendations from its Technical Advisory Body (TAB) on a second set of eligible emissions units (EEUs) for use with offsetting requirements in the initial 2021-2023 pilot phase of CORSIA. This includes the approval of the Architecture for REDD+ Transactions (ART) to supply airlines with national and subnational (jurisdictional) forestry protection carbon credits. ART was the only new second-round applicant to be recommended for immediate eligibility to supply CORSIA EEUs. RSB and ISCC have been approved as sustainability certification schemes for CORSIA eligible fuels.

Commenting on the outcome of the session, Council President Salvatore Sciacchitano said: “ICAO set out a vision for carbon-neutral growth in international aviation and we have now seen that vision bear fruit. The Council’s decisions on eligible emissions units and sustainability certification schemes are the final steps necessary for CORSIA’s timely implementation.”

The approval of EEUs applies for use with offsetting requirements in the pilot phase and are subject to their respective scope of eligibility and eligibility dates. Issued units must be in respect of activities that started their first crediting period from 1 January 2016 and in respect of emissions reductions through 31 December 2020. It requires TAB recommendation and Council approval for an extension to the eligibility timeframes beyond the pilot phase.

TAB has now recommended and the Council approved seven emissions units programmes for eligibility across the two assessment cycles: American Carbon Registry (ACR), Architecture for REDD+ Transactions (ART), China GHG Voluntary Emission Reduction Program, the UN’s Clean Development Mechanism (CDM), Climate Action Reserve (CAR), Gold Standard and Verified Carbon Standard (Verra).

The approval by ICAO of Winrock’s ART and Verra’s Jurisdictional Nested REDD+ (JNR) represents the first acceptance of REDD+ (Reducing Emissions from Deforestation and forest Degradation) standards in a compliance market and is an important moment in the development of REDD+, said the International Emissions Trading Association (IETA).

A paper published by IETA calls for increased investment to prevent deforestation and for carbon markets to channel finance to all pathways that protect, restore and enhance the ecosystems that draw down and store carbon from the atmosphere.

“We need to scale up finance to avoid deforestation – especially tropical deforestation – in a way that contributes to sustainable development goals in forested regions,” said IETA CEO Dirk Forrister.

The paper points out that many countries have included REDD+ activities as part of their Nationally Determined Contributions (NDCs) to the Paris Agreement and that scenario modelling indicates dramatic reductions in deforestation are necessary to help achieve the Paris Agreement’s 1.5C temperature goal.

“Reducing deforestation and the conversion of natural habitats must be prioritised and recognised for its significant climate change mitigation potential in the short-to-medium term,” said Ellen Lourie, Senior Policy Associate at IETA. “If forests are allowed to be destroyed, it won’t be possible to recapture and store the lost carbon in new forests quickly enough to meet the Paris goals.”

Natural Climate Solutions (NCS) is becoming an increasingly large component of the voluntary market, says IETA, and in 2019 forestry and land use represented over 50% of the market by value. The private sector-led Taskforce on Scaling Voluntary Carbon Markets is looking to increase the voluntary market by at least 15-fold by 2030, which, says IETA, represents an opportunity to direct significant new finance into forest protection.

Commenting on the ICAO outcome, Frances Seymour, Chair of the ART board, said: “We applaud the ICAO Council’s decision to approve jurisdictional REDD+ credits from ART. Protecting and restoring tropical forests can contribute up to one-third of the climate results the world needs over the next two decades, representing a massive mitigation opportunity that needs access to private sector capital at scale. ART was designed as a Paris Agreement-aligned, fit-for-purpose crediting programme that provides the assurance of integrity and safeguards that markets need.”

ART, which uses The REDD+ Environmental Excellency Standard (TREES), said its crediting ensures that jurisdictions meet standard market requirements for robust accounting, independent third-party verification and issuance of serialised units on a transparent registry. Despite the impact of the Covid pandemic and the subsequent adjustment to the CORSIA baseline that would delay the need for the airline industry to purchase offsets for compliance with the scheme, the ICAO approval had been interpreted as a ‘seal of quality’ by market participants, said ART. It stated that since the first crediting programmes were approved in March 2020, interest in purchasing CORSIA-eligible credits was increasing from outside the airline industry as a way to ensure they were investing in credible emission reductions.

“ART was established in anticipation of catalytic private sector interest in REDD+, especially in industries with hard-to-abate emissions,” said Mary Grady, Director of the ART Secretariat. “We hope ICAO’s approval provides the needed quality imprimatur for voluntary investments in REDD+ that extends beyond the global aviation sector.”

Mario Boccucci, Head of the UN-REDD Programme Secretariat, commended ICAO’s approval of jurisdictional and national REDD+ crediting programmes, adding: “The UN-REDD Programme is ready to continue to support REDD countries ensure high-quality and environmental integrity, and provide technical assistance to meet NDCs and raise ambition.”

NGO Environmental Defense Fund (EDF) has helped to establish the Emergent Forest Finance Accelerator, a non-profit finance intermediary supported by the Rockefeller Foundation and the Norwegian government’s International Climate and Forest Initiative, to facilitate large-scale REDD+ transactions using the ART framework. It is collaborating with ART, Emergent, the UN REDD Programme and Forest Trends on the ‘Green Gigaton Challenge: Bringing REDD+ to Scale’ that seeks to set a demand signal that can scale up to at least a billion tons per year in emissions reductions transacted from high-integrity jurisdictional REDD+ by 2025.

“ICAO’s decision connects limits on aviation carbon pollution with investments in tropical forest protection and restoration, and is a win for nature, countries, companies and communities,” said Ruben Lubowski, Associate VP for Climate and Forests and Chief Natural Resource Economist at EDF. “After more than a decade of work on REDD+ frameworks under the UNFCCC and other fora, this marks the first time that REDD+ credits have been approved for use within a global compliance carbon market system.

“ICAO’s decision to include large, jurisdictional-scale REDD+ programmes in CORSIA sends a critical signal to companies and policymakers about the value of tropical forest protection to meet climate goals. It shows forest countries that there is a tangible demand for emissions reductions of the highest environmental and social integrity. Approval of these programmes will drive progress in reducing emissions at the scale needed to achieve the climate goals set by the aviation industry and in the Paris Agreement.”

The focus of the TAB and ICAO Council on ensuring programmes obtain from host countries written attestations that they will properly account for the transferred reductions should add to the efforts of Parties in ongoing climate talks to finalise clear guidance to ensure environmental integrity and prevent double-counting of emission reductions, said EDF. The NGO has produced analysis to show global climate cooperation through carbon markets can enable double the emissions reductions under current Paris pledges for the same cost as countries acting alone.

At its November meeting, the ICAO Council also approved two Sustainability Certification Schemes, the Roundtable on Sustainable Biomaterials (RSB) and the International Sustainability and Carbon Certification (ISCC), as eligible to certify CORSIA Eligible Fuels, based on recommendations by ICAO’s Committee on Aviation Environmental Protection (CAEP). The use of such fuels enables aeroplane operators to reduce their CORSIA offsetting requirements from the use of low-carbon and sustainable aviation fuels (SAF) that must be certified by one of the two organisations, although there is a degree of mutual recognition between them. Such fuels must meet the CORSIA Sustainability Criteria, including to achieve net GHG emission reductions of at least 10% compared to the baseline lifecycle emission values for conventional aviation fuel and not be made from biomass obtained from land with high carbon stock.

RSB has developed its own CORSIA Standard which it said goes above and beyond the ICAO scheme’s requirements to ensure that SAF achieves at least 50% GHG reductions on its core lifecycle analysis and a minimum 10% when including CORSIA’s Induced Land Use Change values (ILUC). In addition, it adds, RSB-certified SAF enables further claims around zero deforestation, environmental protection, food security and human rights, as specified in the RSB Principles and Criteria.

RSB is supported and endorsed by many in the aviation industry and also by environmental NGO coalition group ICSA. Airline members of the Sustainable Aviation Fuel Users Group (SAFUG), representing around a third of global commercial aviation fuel consumption, have committed to developing and using fuels consistent with RSB’s sustainability requirements. A third of RSB’s members are from the aviation sector. RSB certificate holders include Gevo, Nuseed, SkyNRG and World Energy, with further commitments to RSB certification from Velocys, LanzaTech and LanzaJet. KLM has committed to sourcing RSB-certified SAF.

Renewable jet producer Neste is also supporting RSB certification standards. “We cordially congratulate RSB for receiving ICAO recognition for its standard and we look forward to continuing the close collaboration,” said the Finnish company’s VP Business Development, Renewable Aviation, Sami Jauhiainen.

“A clear pathway is now available for industry leaders to demonstrate their commitment to sustainability goes above and beyond the legal requirements of CORSIA to also include a full range of social and environmental impacts as well,” commented Rolf Hogan, RSB’s Executive Director, on the ICAO approval. “We look forward to working with these pioneers to implement this new RSB CORSIA Standard to help transform the industry, and the world.”

Added Pedro Piris-Cabezas, Director of Sustainable International Transport and Lead Senior Economist at EDF: “ICAO Council’s approval of RSB is both an outstanding achievement for RSB and a major milestone for CORSIA, which completes CORSIA’s SAF framework. RSB’s CORSIA standard also represents a paradigm shift, moving from RSB’s original focus on sustainable biofuel volumes to a new focus on emissions reductions from the use of SAF for carbon markets.”

ISCC has also expanded the sustainability requirements for CORSIA eligible fuels with additional criteria that aims to protect water, soil, air, biodiversity and workers’ and land rights. “ISCC covers the complete set of CORSIA requirements, allowing economic operators at every point in a fuel’s supply chain to show their compliance with the CORSIA scheme by becoming ISCC CORSIA certified,” said the Germany-based certification body.

Commenting on the Council outcome on eligible units and sustainability certification schemes, ICAO Secretary General Dr Fang Liu said: “The steps that ICAO has taken to address climate change go hand-in-hand with our efforts to promote the sustainable growth and long-term prosperity of international aviation. CORSIA’s implementation elements are ready, and States and airlines are ready to make us of them.”

ICAO has launched a series of videos on ‘Navigating CORSIA’, which are guides to the scheme’s design and implementation.

US environmental groups say the proposal by the Environmental Protection Agency (EPA) to adopt the ICAO CO2 standards for aircraft into US regulations violates the nation’s Clean Air Act because it fails to reduce greenhouse gas emissions despite the EPA’s findings that such emissions endanger public health and welfare. Moreover, they say, the proposal’s failure to consider the statutory factors laid out in the Act or analyse the costs and benefits of a range of possible emission standards, and refusal to select an alternative based on the evidence before the agency was “arbitrary and capricious”. The groups were responding to a public comment period just closed on the proposal, which has been largely supported by US aerospace and airline sectors. Although the majority of aircraft will not be subject to the standards until January 2028, the industry is calling for finalisation of its domestic adoption by the end of this year.

The aircraft CO2 standards were adopted by the ICAO Council in March 2017 and are contained in Annex 16 of the Chicago Convention. It applies to new aircraft type designs from 2020 and to aircraft type designs already in production as of 2023. Those in-production aircraft which by 2028 do not meet the standards will no longer be able to be produced unless their designs are sufficiently modified. The EPA and FAA represented the United States on ICAO’s environmental protection committee CAEP, which drew up the standards.

After legal challenges by environmental groups, in 2016 the EPA issued findings that within the meaning of section 231 of the Clean Air Act, elevated concentrations of greenhouse gas (GHG) emissions in the atmosphere endangered the public health and welfare of current and future generations, and that GHG emissions from certain classes of engines used in certain aircraft are contributing to the air pollution that endangers public health and welfare.

As such, the EPA is proposing to regulate GHG emissions from covered airplanes through the adoption of domestic GHG regulations that match ICAO’s international CO2 standards. Covered airplanes are civil subsonic jet aircraft with a MTOM greater than 5,700 kgs and larger civil subsonic turboprop airplanes with a MTOM greater than 8,618 kgs. It proposes to adopt the ICAO CO2 metric, which measures fuel efficiency, for demonstrating compliance with the GHG emissions standards. The metric is a mathematical function that incorporates the specific air range (SAR) of an airplane/engine combination – a traditional measure of airplane cruise performance in units of km/kg of fuel – and the reference geometric factor (RGF), a measure of fuselage size.

To measure airplane fuel efficiency, the EPA is proposing to adopt the ICAO test procedures whereby the SAR value is measured in three specific operating test points, and a composite of those results used in the metric to determine compliance with the proposed GHG standards. In order to be consistent with the current annual reporting requirement for engine emissions, the EPA is also proposing to require the annual reporting of the number of airplanes produced, airplane characteristics and test parameters.

The EPA says US manufacturers have already developed or are developing technologies that will allow affected airplanes to comply with the ICAO standards, in advance of its adoption, and it anticipates nearly all affected airplanes to be compliant by the respective dates for new type designs and for in-production airplanes. This includes the expectation that existing in-production airplanes that are non-compliant will either be modified and re-certificated as compliant or will likely go out of production before the production compliance date of 1 January 2028.

“For these reasons, the EPA is not projecting emission reductions associated with these proposed GHG regulations,” it states in the executive summary of the proposed rule.

The EPA held a virtual public hearing on September 17, with participation from aircraft and engine manufacturers, aerospace and airline industry associations, environmental organisations and other interested parties. Over 120 written public comments have been submitted in response to the proposal by the October 19 closing date.

A coalition of environmental groups that first filed a suit against the EPA over a decade ago to force the agency to address GHG emissions from aircraft said the proposal violated section 231 of the Clean Air Act (CAA) as it failed to reduce GHG emissions from aircraft despite the EPA’s own endangerment findings.

“Moreover, the proposal’s failure to consider the statutory factors laid out in section 231, over-reliance on factors outside the statute, failure to analyse the costs and benefits of a sufficient range of possible emission standards, and refusal to select an alternative based on the evidence before the agency are arbitrary and capricious,” says the submission by Earthjustice, Center for Biological Diversity, Sierra Club, Friends of the Earth and Natural Resources Defense Council.

“These flaws cannot be remedied in a final rule. Instead, EPA must replace the proposal with one that meets its duties under the Clean Air Act. The final regulations must employ strong mechanisms to reduce emissions from aircraft and protect the public health and welfare and in doing so, EPA must consider the full panoply of available measures, including declining fleetwide emissions averages and operational and design improvements.

“To avoid catastrophic climate change, EPA must implement standards that far exceeds ICAO’s standards in both stringency and scope.”

The submission dismisses the EPA’s argument that US manufacturers would be at a competitive disadvantage if the US failed to adopt standards in line with ICAO’s. “EPA provides no legitimate basis for this assertion. Nothing prevents the US from adopting standards that are more stringent than ICAO’s and EPA has responsibility to do so if that is what public health and environmental protection require.”

Commenting on its own submission, Annie Petsonk, International Counsel for the Environmental Defense Fund, said: “As EPA’s own analysis indicates, the proposed standards will not drive emissions down. It simply embodies what the industry has already baked in. To justify its approach, EPA relied on a problematic estimate of the costs of doing nothing, arbitrarily ignoring the real costs of climate pollution that people across the country are facing every day.

“As the aviation industry tries to bounce back from Covid, it must put addressing the climate crisis at the core of its recovery, and government needs to lead the way. A stringent aircraft pollution standard would mean jobs building the aircraft and creating the fuels of the future. Instead, EPA’s proposed aircraft rule ignores the science and contravenes laws that require it to protect public health and the environment.

“We urge EPA to replace its proposal with standards that will actually reduce aircraft emissions, as one key element of a broader package of carrots and sticks to get the aviation industry to take real steps to cut climate pollution.”

In its submission to the EPA, the non-profit environmental research organisation International Council on Clean Transportation (ICCT) said its analysis showed new deliveries of commercial aircraft in 2019 were on average 6% more fuel efficient than required by the ICAO standards.

With some caveats, the industry response to the EPA’s proposal is supportive of legislation in line with ICAO CO2 standards, which it sees as meeting the criteria set out in the CAA’s section 231.

“Adopting the standards into US law will ensure US-manufactured aircraft and engines are available to US airlines, while fostering global competition and enabling our airlines to acquire aircraft and aircraft engines at market-driven, competitive prices,” says a joint submission by Airlines for America and the Air Lines Pilots Association International. “Especially given that, as the agency itself notes, other ICAO member states that certify airplanes have already adopted the ICAO CO2 standards, the agency needs to act to put US manufacturers on the same footing as their foreign counterparts.”

The two trade bodies said the ICAO standards would achieve GHG emissions reductions, support US policies to combat climate change and provide international uniformity. “Aircraft and the international airspace system simply could not function if aircraft and aircraft engines were subject to disparate regulatory requirements and standards.”

However, they asked the EPA to clarify in its rulemaking that the proposed US standards did not apply to in-service aircraft and disagreed with the agency’s conclusion that there could be no costs or benefits attributable to the standards.

A submission by the Aerospace Industries Association (AIA) said its members had already taken steps to ensure compliance with the proposed standards, including making plans to end production of the least fuel-efficient aircraft.

“The majority of aircraft will not be subject to the standards until 1 January 2028. Nevertheless, we urge the EPA to finalise the domestic adoption of these rules by the end of this year,” said the AIA. “Airlines purchase aircraft several years in advance. They are currently deciding on aircraft that will be delivered through the end of this decade. When making these decisions, airlines will require assurances that aircraft meet the standards to operate in international markets.

“Without domestic regulations in place, the FAA would be unable to certify an aircraft as meeting the ICAO CO2 standards. In this situation, US manufacturers would be at a serious competitive disadvantage if airlines were to seek greater regulatory certainty by opting to purchase aircraft manufactured elsewhere that meet the requirements of their certifying authority’s equivalent rules, which have already been implemented in some cases.

“If this was to occur, it could jeopardise tens of billions of dollars in sales for the US aerospace industry.”

Engine manufacturer GE said the proposed rule would provide the global aviation industry with much-needed certainty and consistency as it faced the Covid crisis and its adoption would satisfy US obligations under the Chicago Convention by ensuring compliance with ICAO standards.

GE also argued that more stringent GHG standards were not appropriate and would potentially violate the Clean Air Act.

“The CAA does not require the EPA to ‘technology force’ at the risk of flight safety,” said the submission. “[It] requires EPA to refrain from changing aircraft emission standards if such a change would adversely affect safety. To maintain the trust and confidence of the flying public, it is imperative that EPA not adopt standards that could in any way be perceived as sacrificing aviation safety. The perception of the flying public matters and EPA should endeavour to avoid any erosion of public confidence in the safety of aviation. This objective is best achieved by EPA remaining aligned with the ICAO analytical criteria of technical feasibility, environmental benefit, cost effectiveness and impacts of interdependencies, which have helped ensure the continuation of aviation’s impressive safety record.

“Moreover, when preparing this proposal, EPA carefully analysed the impacts of two more stringent alternatives. These analyses show that the alternatives would lead to minimal reduction in GHG emissions, while imposing significant costs associated with deviating from the ICAO standards. Consequently, EPA appropriately decided against proposing either of these alternatives.”

While supportive of aligning EPA regulations with the ICAO CO2 standard, both Boeing and Airbus are opposed to the reporting requirements laid out in the proposal. Boeing said they were unnecessary as they were duplicative of FAA reporting requirements, “and unwise because they pose unnecessary risks to Boeing’s confidential business information and potentially the nation’s security.”

The concerns are centred on fears the EPA could make public manufacturers’ specific air range data.

“SAR data is highly sensitive, treated by Boeing and other airplane manufacturers as a trade secret and protected zealously from disclosure to competitors and the public,” says the Boeing submission. “because of the strategic value of SAR data, it can also be subject to federal export controls and sanction regimes.

“There is also a risk that someone could wrongly argue that SAR data should be considered to be emissions data or ‘related technical information’ that EPA must disclose. EPA should not collect SAR data … and should not require reporting of that data. If it nonetheless requires reporting of SAR data then EPA must ensure that data is protected from public disclosure.

“EPA need not collect SAR data to track airplane CO2 emissions performance and verify compliance. ICAO agreed to the use and public reporting of an aircraft’s [fuel efficiency] metric value for this purpose because it is sufficient by itself to enable assessment of compliance with the CO2 emissions standard, while continuing to maintain the confidentiality of manufacturers’ SAR data. Significantly, ICAO does not require public reporting of RGF – an important element of SAR data – precisely because it can be used to derive an airplane’s SAR.”

Airbus too said SAR data and the reference geometric factor were highly commercially sensitive information. It also questioned the EPA’s authority to request such information when a large number of airplanes delivered around the world would never operate within the United States.

“ICAO is the right body to create international standards,” said the Airbus submission. “Airbus believes that in the absence of a worldwide harmonisation process, regional requirements could produce unintended consequences that would harm the aviation industry. We therefore urge the EPA to adopt the proposed ICAO rule with no additional requirements.”

The ICAO Aircraft CO2 standards are contained in Volume III to Annex 16 of the Chicago Convention and were adopted in Europe by the European Parliament and Council in July 2018 (Regulation (EU) No. 2018/1139). The European Union Aviation Safety Agency (EASA) published certification specifications concerning the standard in August 2019.

Photo: Boeing