We have expanded the list of climate policies we assess company engagement with to incorporate land-use related policy, referring to legislative or regulatory measures to enhance and protect ecosystems and land where carbon is being stored. Assessments under this category are currently underweighted in terms of their contribution to the overall company metrics. This weighting will be progressively increased over the next 6 months.
We adjusted the terminology used to describe the queries running down the left-hand side of our scoring matrix and added additional explanatory text to the info-boxes. This has no impact on the scores and methodology. It has been done following user feedback to improve clarity.
Climate Policy Engagement Overview: Airlines for America (A4A) is negatively lobbying climate policy in 2021-23, leveraging its support for global climate regulation at the International Civil Aviation Organization (ICAO) to oppose more ambitious regional and national climate policies in the US and EU. While A4A states top-line support for net-zero emissions for US aviation by 2050, it has lobbied against jet fuel taxes, lower stringency low carbon fuel standards and opposed the inclusion of aviation in the EU Emissions Trading Scheme, while supporting a US blenders tax credit to promote sustainable aviation fuel.
Top-line Messaging on Climate Policy: In March 2021, A4A communicated support for achieving net-zero carbon emissions by 2050 for US aviation as part of its ‘Climate Change Commitment’ report. A July 2022 Twitter post further appeared to urge ICAO to adopt a 2050 net-zero aspirational goal for international aviation in 2022. However, A4A appears to leverage support for weaker global measures to oppose more stringent regional regulations in a January 2021 public consultation response. Similarly, in a September 2021 UK consultation response, A4A appeared to use support for global policies through ICAO to oppose regional regulations. InfluenceMap could not find evidence of the A4A taking a public position on the Paris Agreement.
Engagement with Climate-Related Regulations: In 2021-23, A4A actively opposed the EU Emissions Trading Scheme (EU ETS). In a November 2021 EU consultation response, A4A argued that the inclusion of international intra-EU flights in the EU ETS would be "not legally tenable". In a June 2022 response to the EU Parliament’s proposal A4A argued the extension to departing flights is “in violation of international law”, while A4A CEO, Nicholas Calio, asserted it “directly undermines the…CORSIA agreement” in a June 2022 press release. Additionally, in December 2022 meeting notes between A4A and DG MOVE, obtained via Freedom of Information Request, A4A stated that extending the EU ETS to non-EU flights would “create problems with the US”. Similarly, A4A opposed the application of the UK ETS to international flights, including to the EEA, in a September 2021 UK consultation response.
A November 2021 EU consultation response stated opposition to the EU's proposed SAF mandate, advocating that "If the EU nevertheless proceeds with a mandate: The regulation should not be applied to non-EU carriers' international flights". A4A also opposed a UK SAF blending mandate in a September 2021 consultation response and instead advocated only for incentives. However, in a May 2021 press release, A4A CEO, Nicholas Calio, expressed support for a SAF blenders tax credit legislated under the Sustainable Skies Act. In a December 2022 joint letter submission on the US Clean Fuel Production Credit, A4A supported the tax credit, and a SAF blenders tax credit, while proposing that imported SAF, and SAF used on international flights, should qualify. A4A similarly “strongly supported” the SAF blenders tax credit and Clean Fuel Production Credit in a December 2022 US consultation response.
Regarding state-level SAF policies, A4A appeared to support the inclusion of SAFs in New York’s Clean Fuel Standard on a voluntary opt-in basis, in a July 2022 consultation response. However, A4A appeared to oppose an annually decreasing emission's threshold for jet fuel under California’s Low Carbon Fuel Standard (LCFS), advocating instead for the higher 2019 threshold to be maintained, in June 2022 consultation comments. Similarly, in January and August 2022 comments on California’s LCFS, A4A further questioned the legality of integrating intra-state jet fuel into the LCFS on a mandated basis. In June 2022 comments on Oregon’s Clean Fuel Program, A4A appeared to advocate for less ambitious annual reductions of carbon intensity benchmarks for SAFs. In July 2022 comments, A4A supported Oregon’s amended carbon intensity reductions and further advocated for increased carbon intensity values for SAFs for 2023-24.
Through the ‘SAF BTC Coalition’, A4A appeared to advocate for weaker sustainability criteria for SAFs to protect land-based carbon stores under the SAF blenders tax credit and Clean Fuel Producers Credit in February 2023 and December 2022 US consultation responses. Furthermore, A4A opposed a cap on crop-based biofuels under California’s Low Carbon Fuel Standard in March 2023 and August 2022 consultation responses.
Positioning on Energy Transition: Despite supporting the increased use of SAF in aviation, A4A appears opposed to measures to transition aviation’s energy mix. In comments on California’s 2022 Scoping Plan Update, A4A supported the proposed aviation decarbonization scenario of 10% of emissions reductions from electric and hydrogen propulsion, alongside 90% from SAFs. However, in comments on New York’s Climate Action Scoping Plan, A4A appeared supportive of decarbonization scenarios dependent on SAF deployment, while opposing scenarios reliant on zero-emissions technologies.
An A4A spokesperson appeared to oppose a New York jet fuel tax, stating it would hinder aviation’s recovery from Covid-19 in a December 2021 Prospect article. Additionally, in December 2022 meeting notes with DG MOVE, A4A expressed concern regarding the Netherland’s proposed flight cap at Schiphol airport. Furthermore, in a September 2021 consultation response, A4A appeared to question the legality of a jet fuel tax on international flights by asserting a tax on fuel would violate agreements between the UK and the US and Canada.