Climate Lobbying Overview: Airlines for Europe (A4E) appears to be actively lobbying European climate policy for aviation, with mostly negative engagement in 2020-22. While A4E has stated top-line support for 2050 net-zero European aviation emissions and the Paris Agreement, it has lobbied against numerous EU climate policies to reach such a target, including an EU kerosene tax.

Top-line Messaging on Climate Policy: In a July 2021 and January 2022 emails to DG CLIMA, accessed by InfluenceMap via FOI request, A4E endorsed net-zero European emissions for aviation by 2050 while communications from the 2021 ‘Destination 2050’ report suggest support for the Paris Agreement. A4E also appeared to support a global long-term 2050 CO2 aspirational goal for aviation at ICAO in a February 2022 press release and an October 2022 press release after its adoption by ICAO. However, in a November 2022 position paper, A4E appeared unsupportive of incorporating non-CO2 emissions into current climate regulations, instead advocating for a “bespoke” approach. A4E also appears to have communicated opposition to numerous stringent EU and national-level climate regulations to decarbonize aviation. In multiple EU consultation responses from 2020-21, A4E stated “regional climate solutions risk shifting CO2 at the expense of airlines in the region”, instead appearing to promote global regulations. However, in a February 2022 Flight Global article, A4E’s Managing Director, appeared to advocate for European and national policies alongside a “strong global framework…matching Europe’s ambition”, suggesting a supportive position towards more ambitious global policy.

Engagement with Climate-Related Regulations: A4E appears to have mostly negative engagement around the inclusion of aviation in the EU Emissions Trading System (EU ETS), while having more mixed engagement around an EU SAF mandate. In multiple 2020-21 EU consultation responses, A4E stated opposition to including international (EEA to/from non-EEA) flights in the EU ETS and appeared to question the legality of this extension. Evidence from a May 2022 Fact Sheet and November 2021 position paper suggests A4E also supports a hybrid EU ETS and CORSIA scheme to apply to intra-EEA flights (EEA to/from EEA). In January 2022 and March 2022 position papers, A4E also seemed to advocate for free EU ETS emissions allowances to be extended beyond 2027. A May 2022 joint letter, signed by A4E, further advocated for continued allowances based on SAF usage. In response to the EU Parliamentary position in June 2022, A4E appeared unsupportive of the inclusion of all flights departing the EEA and a phase-out of free emission allowances by 2025 in the EU ETS. Furthermore, June 2021 meeting notes between A4E CEO’s and DG MOVE, accessed via FOI, suggest support for a slower reduction in free emissions allowances and the implementation of CORSIA with “minimum deviation”. While A4E further appears to leverage support for ICAO’s global CORSIA offsetting scheme to oppose more stringent climate regulations, in a January 2022 position paper, A4E appeared to oppose strengthening CORSIA through the implementation of a 2019-2020 baseline by the EU Commission. However, A4E appears to have consistently stated general support for the EU ETS for aviation, including in a July 2021 statement.

A4E appears to have mixed engagement on an EU sustainable aviation fuels (SAF) mandate. In January 2022 and March 2022 position papers, A4E appears to advocate that an EU SAF mandate should only be introduced under a mature market. Similarly, A4E’s Managing Director, Thomas Reynaert, stated that introducing a blending mandate “too soon-today-will have a major environmental and economical detrimental impact” in a February 2021 AIN Online report. Furthermore, in a June 2022 press release, Reynaert appeared to oppose a more ambitious 6% SAF mandate by 2030, and the possibility of national mandates, as proposed by the EU Council, while supporting a 5% 2030 SAF mandate. More positively, both a position paper and EU consultation response in November 2021 appeared to support the proposed EU SAF mandate and an e-fuels sub-mandate.

In response to a February 2021 public consultation, A4E also appeared supportive of sector-specific renewable energy targets under the Renewable Energy Directive. A November 2021 A4E EU consultation response further appeared to oppose applying the EU's Energy Efficiency Directive to sectors already covered by the EU ETS (such as aviation).

Positioning on Energy Transition: In 2020-22, A4E seems to have actively advocated against numerous EU measures to decarbonize aviation. Comments from A4E's Managing Director in September 2021 at the Airbus Summit described an EU kerosene tax as the "least effective measure to effectively reduce CO2". Furthermore, according to multiple position papers from 2020-22, A4E are “categorically opposed” to an EU kerosene tax, describing the measure as “ecologically and economically counterproductive” while emphasizing impacts on competitive distortion. In June 2021 meeting notes between A4E CEO’s and DG MOVE, accessed via FOI, A4E further appeared to directly advocate against an EU jet fuel tax. At the A4E Aviation Summit in March 2022, A4E Managing Director also appeared to oppose the Belgium ticket tax, stating “it is simply made for the revenue, there is no environmental rationale at all”. However, a March 2022 position paper indicates A4E’s support for the Alternative Fuels Infrastructure Directive to stationary aircraft, with the exception it only applies to airports with over 1 million passengers/year.