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 Lobbying Overview: Airlines for America (A4A) is negatively lobbying climate policy in 2020-22, 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 in 2021 stated top-line support for net-zero emissions for US aviation by 2050, it has lobbied against jet fuel taxes, opposed the inclusion of aviation in the EU Emissions Trading System and rejected sustainable fuel mandates, while supporting a US blenders tax credit to promote sustainable aviation fuel.
Top-line Messaging on Climate Policy: A4A’s top-line communications in 2020-22 have generally stated support for international climate policy for aviation while opposing more ambitious regional and national climate action. 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. An October 2022 press release supported the adoption of a 2050 CO2 net-zero aspirational goal for international aviation at ICAO, while A4A CEO, Nicholas Calio, stated A4A “stand ready to work in partnership with the Biden administration” in response to climate change, in a February 2021 independent article. However, A4A’s‘Climate Change Commitment’ report does not appear supportive of IPCC-aligned policies in the near-term to reach net-zero by 2050. Furthermore, in a September 2020 EU consultation response, A4A appeared to support incentives over binding emissions reductions regulations to decarbonize aviation. A4A further appears to leverage support for weaker global measures to oppose more stringent regional regulations in a January 2021 public consultation response.
Engagement with Climate-Related Regulations: In 2021-22, A4A has communicated support for ICAO’s CORSIA emissions mitigation scheme over other binding emission reduction regulations. However, A4A in 2020 appeared to support measures to weaken the CORSIA offsetting scheme, by endorsing a change to its baseline date to include only 2019 emissions, substantially weakening the emissions reduction potential of CORSIA.
In 2020-22, A4A actively opposed the EU Emissions Trading Scheme (EU ETS). In a 2020 EU consultation response, A4A opposed expanding the EU ETS to international (non-EEA to/from EEA) flights, suggesting it may be illegal, and advocating to repeal the application of the EU ETS to aviation and replace it with the global CORSIA offsetting scheme. In another November 2021 EU consultation response, A4A similarly argued that the inclusion of international intra-EU flights in the EU ETS would be "not legally tenable" as "the international flights of an aircraft operator cannot be subject to an emissions scheme other than CORSIA". A4A further stated “CORSIA is the only MBM applicable to CO2 emissions from international aviation, and for the EU to ignore it would be to disregard international law”, in a January 2021 consultation response. In a June 2022 response to the EU Parliament’s proposed extension of the EU ETS to flights departing the EEA, A4A argued the extension is “in violation of international law”, while A4A CEO, Nicholas Calio, asserted it “directly undermines the…CORSIA agreement”. In a January 2021 response to an EU public consultation, A4A also stated it “does not support carbon taxation”.
In 2019-22, A4A appear to support policies incentivizing SAF production while opposing SAF mandates. In its 2020 report on “Sustainable Aviation Fuel”, A4A stated opposition to sustainable aviation fuel mandates in the US, emphasizing costs concerns. Similarly, in an October 2020 EU consultation response, A4A rejected EU SAF mandates as they are “a long way from being commercially viable at scale”, while a September 2020 consultation response appeared to encourage the EU Commission not to mandate SAF quotas. Moreover, a November 2021 EU consultation response stated opposition to the EU's proposed SAF mandate, further advocating that "If the EU nevertheless proceeds with a mandate: The regulation should not be applied to non-EU carriers' international flights". However, in numerous communications from 2021-22, A4A also appeared to express support for a "blenders tax credit" to promote US SAF use. In a May 2021 press release, A4A CEO, Nicholas Calio, also expressed support for the Sustainable Skies Act, which proposes a SAF-specific blenders tax credit. Additionally, a September 2020 public consultation response indicated support for California’s low-carbon fuel standard, describing it as “the most effective policy incentive for SAF”. In a September 2020 EU consultation response, A4A also advocated for a higher multiplier for SAF under the Renewable Energy Directive.
A4A has consistently supported ICAO’s global CO2 standard for aviation, including on its website in 2021. In 2020, A4A vocally advocated to the US government to certify ICAO’s global CO2 standard into US law. However, this support was qualified by major exceptions, urging the US government in a 2020 consultation response not to introduce a more ambitious CO2 standard than set by ICAO, and that such standards should not apply to in-service aircraft.
Positioning on Energy Transition: Despite supporting the increased use of SAF in aviation, A4A appears opposed to measures to decarbonize aviation and transition the energy mix. In 2020, evidence suggests that A4A opposed measures to add green conditions to US COVID-related bailouts for the airline industry, arguing that such conditions may “render the loans unusable, because the process provided to businesses via U.S. bankruptcy law is more attractive”. A4A opposed an EU jet fuel tax in a 2020 consultation response, questioning its legality. 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. Furthermore, in response to a UK public consultation, A4A appeared to advocate for the UK’s Air Passenger Duty, a ticket tax on flights, to be abolished and stated “at the very least, A4A urges the government to suspend APD” in response to the Covid-19 pandemic. In the same consultation response, A4A also appeared opposed to a frequent flyer levy.