Airlines For Europe (A4E)

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Climate Lobbying Overview: Airlines for Europe (A4E) appears to be actively lobbying European climate policy for aviation with mostly negative engagement in 2019-21. While Airlines for Europe has stated top-line support for 2050 net-zero European aviation emissions, it has actively lobbied against numerous near-term EU climate policies to reach such a target, including an EU jet fuel tax, and expanding the scope of the EU ETS to fully include all international flights, while evidence from November 2021 suggests support for an EU sustainable aviation fuels mandate.

Top-line Messaging on Climate Policy: Airlines for Europe appears to have supported a long-term net-zero 2050 target for European aviation emissions, while opposing stringent EU and national-level climate policy to reduce aviation’s GHG emissions in Europe. A4E communications in 2019-20 appeared to have an unclear position regarding an EU 2050 net-zero target, while supporting a 2°C global warming target. However, as part of the Aviation Roundtable Report in November 2020 and the Destination 2050 strategy outlined in February 2021, A4E endorsed net-zero European emissions for aviation by 2050 and a 55% reduction in net CO2 emissions from intra-EU flights. Further communications from A4E in 2021 also suggest support for the Paris Agreement.

However, A4E appears opposed to specific stringent EU and national-level climate regulations to decarbonize aviation, instead prioritizing global measures like CORSIA in a 2020 position paper. Moreover, in a 2020 EU consultation response A4E stated that “regional climate solutions risk shifting CO2 at the expense of airlines in the region.” Airlines for Europe in 2019-21 have also consistently emphasized concerns around costs and “competitive disadvantages” regarding EU climate action for aviation, prioritizing aviation growth over IPCC demanded emissions reductions in their communications. In 2021, A4E signed a joint commitment supporting EU aviation climate policy involving government-created market-based solutions, without clearly specifying what policies this referred to.

Engagement with Climate-Related Regulations: Airlines for Europe appear to leverage their support for ICAO’s global CORSIA offsetting scheme to oppose more stringent European climate regulations. A4E in 2020 stated support for ICAO’s CORSIA emissions mitigation scheme under which airlines must buy offsets for emissions beyond an average baseline emissions of 2019, and/or use ‘CORSIA eligible’ fuels (a voluntary scheme until 2027). However, evidence suggests A4E supported measures to weaken the CORSIA offsetting scheme in a May 2020 position paper, endorsing a change to CORSIA’s baseline date to include only 2019 emissions compared to an average of 2019-20 emissions, reducing the emissions reduction potential of the scheme.

A4E has opposed nearly all other key strands of ambitious EU climate legislation for aviation in 2019-21. In multiple 2020-21 EU consultation responses, Airlines for Europe stated opposition to including international (EEA to/from non-EEA) flights in the EU Emissions Trading System and appeared to question the legality of extending the EU ETS to international non-EEA flights. Furthermore, evidence suggests A4E supports a hybrid EU ETS and CORSIA scheme to apply to intra-EEA flights (EEA to/from EEA), including in a November 2021 position paper. A4E also appeared to argue a change in free allowances from the EU ETS for aviation should be delayed until after the COVID-19 pandemic in a January 2021 consultation response. In a February 2021 consultation response, A4E further supported the continued allocation of free emissions permits for aviation in the EU ETS. In a June 2021 meeting with the EU Commission, A4E appeared to emphasize carbon leakage concerns and the COVID-19 pandemic to suggest free allowances should be reduced gradually. Moreover, in a November 2021 position paper, A4E advocated for free emissions allowances in the EU ETS to be extended beyond 2027. A November 2021 EU consultation response from A4E further appeared to oppose applying the EU's Energy Efficiency Directive to sectors already covered by the EU ETS (such as aviation).

Airlines for Europe stated in a 2020 consultation response that a sustainable aviation fuels (SAF) mandate should be only considered in the future under “mature market conditions”, suggesting it would not support a mandate in the near-term. Furthermore, A4E’s Managing Director, Thomas Reynaert, stated in 2020 that regarding SAFs, “such legislation needs to prioritise additional incentives for aviation, instead of putting in place compulsory mandates for blending irrespective of price, production volumes or competitiveness considerations.” However, in November 2020, as part of the Aviation Round Table report, A4E appeared to endorse an EU SAF blending mandate and in September 2021, A4E's Managing Director appeared to state support for an EU SAF blending mandate during an interview at the Airbus Summit. Additionally, both a position paper and EU consultation response in November 2021 from A4E appeared to support the proposed EU SAF mandate and a sub e-fuels mandate.

In April 2021, Airlines for Europe signed a joint letter from EU businesses that called on the US government to support a 50% economy-wide GHG emissions reduction target for 2030.

Positioning on Energy Transition: In 2019-21 Airlines for Europe seems to have actively lobbied against numerous EU measures to decarbonize aviation. In 2020, A4E stated opposition to a jet fuel tax in a 2020 EU consultation, further asserting in an October 2020 policy paper that a jet fuel tax would “reduce the global competitiveness of European airlines” and opposing a proposed intra-EU EU jet fuel tax in July 2021 media comments. Further comments from A4E's Managing Director in September 2021 at the Airbus Summit appeared to oppose an EU jet fuel tax as the "least effective measure to effectively reduce CO2", with A4E continuing to opposing such a tax in a position paper and an EU consultation response, both in November 2021.

In a March 2020 press release, A4E advocated for a moratorium on new aviation taxes during the COVID-19 pandemic. A4E’s Managing Director also argued in a February 2020 media piece that “not one single study” shows that ticket nor fuel taxes impact passenger behavior enough to “very much decrease” aircraft traffic. Airlines for Europe has further consistently opposed national-level European aviation ticket taxes. An October 2020 A4E paper recommended that governments "steer clear of quick fixes (e.g. ticket taxes) to pressing and complex environmental challenges". In 2019-20, A4E stated opposition to a Netherlands ticket tax on Twitter, and A4E’s Managing Director, appeared unsupportive of the UK Air Passenger Duty in a November 2020 media interview. However, A4E has stated support for greater EU investment and policy interventions to promote the electrification of aviation.